Stroock Special Bulletin
"CFTC Adopts Interim Rule under Dodd-Frank Regarding the Reporting of Pre-Enactment Swap Transactions and Proposes a Definition of Agricultural Commodity"
The Commodity Futures Trading Commission (the "CFTC") recently issued two releases under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). The first release, issued on October 14, 2010, addresses the CFTC's adoption of an interim final rule requiring the reporting of certain information relating to swap transactions entered into prior to the enactment of the Dodd-Frank Act (the "Interim Final Rule"). The second release, issued on October 26, 2010, sets forth the CFTC's proposed definition of "agricultural commodity" as necessitated by the Dodd-Frank Act.
This Stroock Special Bulletin highlights the major provisions of these CFTC releases.