• CFTC Proposes Key Rulemakings that Complete the "Mosaic" of Proposed Rules to Implement Title VII of the Dodd-Frank Act
  • May 2, 2011
  • Law Firm: Sutherland Asbill Brennan LLP - Washington Office
  • The Commodity Futures Trading Commission (“CFTC”) held an open meeting yesterday to issue several key proposed rulemakings that, together with the CFTC’s other proposed rulemakings to date, complete the so-called “mosaic” of CFTC proposed rules to implement Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).1 Topics addressed by yesterday’s proposed rules include definitions for the terms “swap”, “security-based swap” and “security-based swap agreement” (collectively the “product definitions”) as well as capital requirements for swap dealers and major swap participants, segregation of cleared swaps customer collateral and conforming amendments to existing CFTC regulations. The Securities and Exchange Commission (“SEC”) also held an open meeting yesterday to consider the proposed rule on the product definitions, which is a joint proposed rule by the CFTC and the SEC.