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CFTC issues proposed rule regarding reporting and recordkeeping for pre-enactment and transition swaps

05 May 2011

Energy Alert

The Commodity Futures Trading Commission (Commission or CFTC) issued a proposed rule, 76 Fed. Reg. 22,833 (25 April 2011), setting out reporting and recordkeeping requirements for pre-enactment and transition swaps (historical swaps). "Pre-enactment swaps" are swaps entered into before the date of enactment of the Dodd-Frank Act and "transition swaps" are swaps entered into after the date of enactment of the Dodd-Frank Act but prior to the compliance date that the Commission will specify in its final swap data reporting and recordkeeping rules (Compliance Date).

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