Notice & Comment

Securities, Commodities, and Exchanges: CFTC Issues Proposed and Interim Final Rules for Dodd-Frank Implementation, by Jonathan Rusch

From October 14 through November 3, the Commodity Futures Trading Commission (CFTC) published in the Federal Register a series of nine sets of proposed rules and interim final rules to implement various provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). The notices include an interim final rule for reporting pre-enactment swap transactions (October 14); a notice of proposed rulemaking (NPR) on financial resources requirements for derivatives clearing organizations (October 14); an NPR on requirements for derivatives clearing organizations, designated contract markets, and swap execution facilities regarding the mitigation of conflicts of interest (October 18); an ANPR on antidisruptive practices authority in Dodd-Frank (November 2); an NPR on the process for review of swaps for mandatory clearing (November 2); an NPR on position reports for physical commodity swaps (November 2); an NPR requiring the CFTC to remove any reference to or reliance on credit ratings in Commission regulations, and proposing alternatives to the use of credit ratings (November 2); an NPR on new authority prohibiting market manipulation (November 3); and a proposed rule on investment of customer funds and funds held in an account for foreign futures and foreign options transactions (November 3).

This post was originally published on the legacy ABA Section of Administrative Law and Regulatory Practice Notice and Comment blog, which merged with the Yale Journal on Regulation Notice and Comment blog in 2015.