CFTC Staff Letter 11-04: No-Action Relief for DCIO and DMO Provisions Effective July 16, 2011

CFTC Letter No. 11-04
No-Action
July 14, 2011
Division of Clearing and Intermediary Oversight Division of Market Oversight Staff No-Action Relief: Application of certain CEA provisions after July 16, 2011 – the general effective date of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act. On July 21, 2010, President Obama signed the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).1 Title VII of the Dodd-Frank Act amends the Commodity Exchange Act (“CEA”)2 to establish a comprehensive regulatory framework for swaps.3
Section 754 of the Dodd-Frank Act states that, unless otherwise provided, the
provisions of subtitle A of title VII4
“shall take effect on the later of 360 days after the date of the enactment of this subtitle or, to the extent a provision of this subtitle requires a rulemaking, not less than 60 days after publication of the final rule or regulation implementing such p of this subtitle.” The date 360 days after the date of enactment is July 16, 2011. To impleme the Dodd-Frank Act, the Commission has thus far issued 52 advance notices of proposed rulemaking or notices of proposed rulemaking, two interim final rules, six final rules, and on proposed interpretive rovision nt e order.