Proposed Amendments Regarding Effective Date for Swap Regulation

SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed amendments regarding the effective date for swap regulation, 76 Fed. Reg. 65,999. The proposed amendments would affect to the July 14, 2011 final order that granted temporary exemptive relief from certain provisions of the Commodity Exchange Act (CEA) that would have otherwise become effective on July 16, 2011 under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  While SIFMA supports the CFTC’s decision to amend the July 14 Order, it reiterates some of the concerns not addressed in the current proposed amendments, but raised  n SIFMA’s previous comments, which include the inadequacy of temporary exemptive relief and the need for a comprehensive implementation schedule.