"CFTC and SEC Provide Temporary Dodd-Frank Effective Date Relief"

Sections 754 and 774 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") provide that, except as otherwise specified, the provisions of Subtitles A and B of Title VII of the Dodd-Frank Act in respect of swaps and security-based swaps, respectively, "shall take effect on the later of 360 days after the date of enactment of [the Dodd-Frank Act] or, to the extent a provision of [the Dodd-Frank Act] requires a rulemaking, not less than 60 days after publication of the final rule or regulation implementing such provisions of [the Dodd-Frank Act]."

The date that is 360 days after the date of enactment is July 16, 2011 (the "Effective Date").

This Stroock Special Bulletin discusses recent steps that the U.S. Securities and Exchange Commission and Commodity Futures Trading Commission have taken to address market uncertainty related to the Effective Date.