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Anticipated Compliance Dates for CFTC Swap Regulations

A recent K&L Gates alert discusses when the CFTC regulations on OTC swaps will likely take effect.  At its open meeting on September 8, 2011, the CFTC proposed a schedule that would phase-in the compliance dates of rules governing mandatory swap clearing and trade execution, margin requirements for uncleared swaps, and margin documentation requirements.  It appears that mandatory clearing of swaps will not likely "go live" until late 2012.  The exact compliance date for a market participant's compliance date will depend on the type of entity it is (for these purposes the CFTC has grouped market participants into 4 distinct categories).   Similarly, the effectiveness date for documentation and margin requirements will depend on the type of market participants involved in a swap transaction.  The current effectiveness schedule is dependent on  several final rules being adopted by the CFTC and is therefore subject to change.  A full analysis of the anticipated phase-in of the swap regulations is available in the K&L Gates alert.