• SEC and CFTC Request Comments on Significant Defined Terms in Title VII of Dodd-Frank
  • September 15, 2010 | Authors: James M. Cain; Warren N. Davis; William H. Hope; Mark D. Sherrill; Paul B. Turner
  • Law Firms: Sutherland Asbill & Brennan LLP - Washington Office ; Sutherland Asbill & Brennan LLP - Atlanta Office ; Sutherland Asbill & Brennan LLP - Washington Office ; Sutherland Asbill & Brennan LLP - Houston Office
  • The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have recently undertaken the unprecedented task of implementing the multitude of regulatory changes recently brought about by the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act) signed into law in July, and in particular, under Title VII of the Act, known as the Wall Street Transparency and Accountability Act of 2010. At the heart of the regulations to be adopted by the SEC and the CFTC under Title VII of the Act are regulations needed to further define Title VII's definitions of "swap," "security-based swap," "swap dealer," "security-based swap dealer," "major swap participant," "major security-based swap participant," "eligible contract party," "security-based swap agreement," and "mixed swap." To assist the SEC and the CFTC in adopting regulations to further define and clarify the meaning of these terms, these regulators have issued a release requesting comments on the definitions. These comments must be submitted by September 20, 2010.