"CFTC & SEC Issue Final Release Defining “Swap Dealer,” “Major Swap Participant” and Other Key Terms"

On April 18, 2012, the Commodity Futures Trading Commission and Securities and Exchange Commission ("SEC," and together with the CFTC, the "Commissions"), in consultation with the Board of Governors of the Federal Reserve System, published final rules (the "Final Rules"), an interim final rule and interpretive guidance under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, further defining the terms "swap dealer," security-based swap dealer, "major swap participant," "major security-based swap participant," and "eligible contract participant."

This Stroock Special Bulletin highlights major provisions of the Final Rules, interim final rule and interpretive guidance.