On December 20, 2011, the CFTC approved a final rule on Swap Data Recordkeeping and Reporting Requirements. In the Final Rule, the Commission sets out the data reporting and recordkeeping framework applicable to SDRs, DCOs, SEFs, DCMs, SDs, MSPs and swap counterparties who are not registered as either an SD or an MSP. This Alert highlights certain material provisions of the Final Rule, including certain interesting changes to the notice of proposed rulemaking previously issued by the Commission in connection with the Final Rule, together with a discussion of extraterritorial scope.