December 13, 2012
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Almost four years after the financial crisis and over two years after the passage of the Dodd Frank Wall Street Reform and Consumer Protection Act, the overhaul of the US derivatives market is rapidly shifting into the implementation phase. Many of the key elements of Dodd Frank relating to OTC derivatives have begun to take effect on October 12, 2012, although the CFTC has delayed implementation of some requirements until the beginning of 2013.
This handbook provides an overview of the key requirements and issues that End Users need to consider as they enter the implementation phase of Dodd Frank. As a reference tool, we have provided a table summarizing the required compliance timeline for the various elements of Dodd Frank that End Users may need to comply with, including recordkeeping and reporting requirements, adopting board resolutions to take advantage of the clearing exception offered to End-Users and amending swap documentation as appropriate.