Effective Dates for Certain Swap Regulations

SIFMA, the American Bankers Association, the ABA Securities Association, the Futures Industry Association, the Institute of International Bankers, the International Swaps and Derivatives Association, and the Investment Company Institute provide comments to the Commodity Futures Trading Commission (CFTC) on the Proposed Order regarding Effective Date for Swap Regulation (76 Fed. Reg. 35,372); Request for No-Action Relief; and Petition for Exemption Pursuant to Section 4(c) of the Commodity Exchange Act. The Proposed Order regards the effective dates of various key provisions under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The groups write to request that the CFTC clarify certain ambiguities raised by the Proposed Order and, where appropriate, grant additional relief to enhance legal certainty and ensure an orderly and coordinated implementation process.