Publication of “Swap” Definition Finalizes Compliance Dates

Law firm Leonard Street and Deinard published a simple update on the DFA compliance dates here: http://dodd-frank.com/publication-of-swap-definition-finalizes-compliance-dates

The short answer is this:

October 12, 2012

• Swap Dealers (SDs) and Major Swap Participant (MSPs): Registration, Internal Business Conduct Standards, Reporting and Recordkeeping Requirements for Interest Rate and Credit Swaps
• Position Limits (Spot Month)
• Large Trader Reporting

January 10, 2013

• SDs and MSPs: Reporting and Record-keeping Requirements for All Swaps

April 10, 2013

• End Users: Reporting and Record-keeping Requirements for All Swaps

A recap of important definitional concepts and compliance obligations related to the term “swap,” particularly as concerns energy companies, is available here.