The Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") imposes certain recordkeeping and reporting obligations on parties to swap transactions. While compliance with the final reporting rules passed in December of 2011 is not yet required, the CFTC currently imposes a recordkeeping obligation of transaction data by parties to a swap transaction entered into at any time after the enactment of Dodd-Frank on July 21, 2010 or that were unexpired as of such date.
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