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