Interesting point being made – you can’t register as an SD / MSP until you’ve counted the notional on the trades you’re doing from the start point of the regulations, hence a potential time gap before registration occurs, and therefore the obligation to clear and report. Could be a boon to project planners who can add three months into their compliance planning? Anyone else agree?
Swap Dealers May Get Until January to Complete CFTC Registration – Bloomberg.

August 17, 2012 


yes, that´s how the process for the registration requirement is set up – tricky to find in the rule, though (especially if you don´t know that you expect something like this)