New Recordkeeping Requirements for Swaps – Teigland-Hunt LLP Client Alert

The Commodity Futures Trading Commission (“CFTC”) recently issued an interim final rule (the “Rule”) requiring the reporting of swap transactions that were open as of July 21, 2010, the date of enactment of the Dodd‐Frank Act (“Pre‐Enactment Unexpired Swaps”). Comments onthe Rule will be accepted by the CFTC until November 15, 2010.