Alert September 18, 2012

CFTC Issues FAQ on Timing of Swap Dealer Registration

The CFTC issued a list of frequently asked questions on the timing of swap dealer registration.  Among other things, the FAQ clarifies that, despite the October 12 compliance date for the CFTC regulations requiring the registration of swap dealers, “a person that takes advantage of the de minimis exception in CFTC regulation § 1.3(ggg)(4), as any person is permitted to do, would not be a swap dealer on October 12, 2012 and would not be required to apply to be registered on that date.”  Effectively, therefore, the FAQ provides that the registration deadline for a swap dealer is December 31, 2012.