Alert May 03, 2011

CFTC Proposes Rules Requiring Swap Data Recordkeeping and Reporting

The Commodity Futures Trading Commission (the “CFTC”) issued a proposal that would establish recordkeeping and reporting requirements for swaps entered into before July 21, 2010, the date of enactment of the Dodd-Frank Act, whose terms had not expired as of that date, and data relating to swaps entered into on or after July 21, 2010 and prior to the compliance date specified in the CFTC’s final swap data reporting rules.  The proposal addresses the records, information and data that must be retained for historical swaps, the timeframe for reporting data to a swap data repository or the CFTC and the specific data to be reported.  Comments on the proposal are due by June 9, 2011.