Clifford Chance

CFTC Proposes Schedule for Swap Rules

22 September 2011

On September 8, 2011, the U.S. Commodity Futures Trading Commission (the "CFTC") issued two proposed rules addressing the timetable for implementation of new regulatory requirements for swaps under the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank"). One of these proposals relates to the implementation schedule for clearing and trade execution requirements (the "Cleared Swaps Implementation Proposal"); the other relates to the implementation schedule for documentation and margin requirements for uncleared swaps (the "Uncleared Swaps Implementation Proposal"). On the same day, CFTC Chairman Gary Gensler also issued a tentative schedule for finalizing various other derivatives-related rules to be promulgated under Dodd-Frank (the "Final Rules Schedule").

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