August 14, 2012
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.