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Reporting The Future: The CFTC’s Final Rule On Real-Time


The Final Rule implements Section 727 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the DFA) and provides for the real-time reporting of swap transaction and pricing data by swap data repositories, swap execution facilities, designated contract markets, swap dealers, major swap participants and swap counterparties who are not registered as either a swap dealer or a major swap participant.

The attached article  sets out a summary of some of the points of interest in the Final Rule. The Final Rule differs in certain material respects from the notice of proposed rulemaking previously issued by the Commission in connection with the Final Rule, and we highlight some of these in the attached, together with a discussion of extraterritorial scope. In general, many of the changes respond to comments received by the Commission and reflect welcome improvements to the notice of proposed rulemaking.  We have also attached to the article diagrams illustrating the time delays for the reporting of block trades and the phased compliances dates.




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