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  • Outline of Final Dodd-Frank Title VII Rules the CFTC May

    Consider in 2011 and the First Quarter of 2012

    Remainder of 2011

      • Clearinghouse Rules

      • Data Recordkeeping and Reporting

      • End-User Exception

      • Entity Definitions/Registration

      • External Business Conduct

      • Internal Business Conduct (Duties, Recordkeeping and Chief Compliance Officers)

      • Position Limits

      • Product Definitions/Commodity Options

      • Real-Time Reporting

      • Segregation for Cleared Swaps

      • Trading – Designated Contract Markets and Foreign Boards of Trade

    First Quarter 2012

      Capital and Margin

      Client Clearing Documentation and Risk Management

      Conforming Rules

      • Disruptive Trading Practices

      • Governance and Conflict of Interest

      • Internal Business Conduct (Documentation)

      • Investment of Customer Funds

      • Swap Execution Facilities

      Segregation for Uncleared Swaps

      Straight-Through Trade Processing

    Note: This outline is tentative and for preliminary purposes, and is subject to change.

    Last Updated: September 9, 2011