Alert December 21, 2010

CFTC Issues Interim Final Rule Regarding Reporting Certain Post Enactment Swap Transactions

The CFTC issued a release adopting and seeking comment on an interim final rule for the reporting of certain post-enactment swap transactions entered into on or after July 21, 2010.  The proposal is designed to implement Section 723 of the Dodd‑Frank Act.  The interim final rule was effective December 17, 2010 and will remain in effect until the operative date for permanent recordkeeping and reporting rules for swap transactions to be adopted by the CFTC.  The CFTC is seeking comment on all aspects of the interim final rule; comments are due on or before January 18, 2011.