Dodd-Frank Act - Effective Date for Swap Regulation - Comment Letter - CME Group - July 1, 2011

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Dodd-Frank Timeline, Order to Address Effective Date for Swap Regulations, CFTC
2nd Proposal Date Comment Deadline Extension Date
May 16, 2012 May 30, 2012 December 31, 2012

Proposed Order Regarding Effective Date for Swap Regulation
July 1, 2011

From the comment letter:

"In addition to recommending that the exemptive relief expire on the sooner of July 16, 2012 or final, effective rules governing the provision at issue, we recommend that the Commission:

  • interpret Section 754 of Dodd-Frank to include Category 2 provisions, thereby treating Category 1 and 2 provisions the same under the Proposed Order;
  • provide 4(c) relief to Exempt Commercial Markets (“ECMs”) and Exempt Boards of Trade (“EBOTs”) that begin operating on or after July 16; and
  • confirm that additional exemptive relief is not needed for a DCM to list swaps for trading on or after July 16 so long as those products are regulated as futures products and market participants trading those products are regulated as futures market participants.


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