In the space of a few days in mid-October, the Commodity Futures Trading Commission (the "CFTC") published a number of Q&As and FAQs and the CFTC staff at the Division of Swap Dealer and Intermediary Oversight (the "Divisio") and the Office of General Counsel ("OGC") published several interpretative and no-action letters. Each publication addressed the implications of or provided clarity with respect to a number of rulemakings that were set to become effective on October 12, 2012. October 12, 2012 was a key date in the Dodd-Frank regulatory reform calendar, as this is the date upon which the joint CFTC and Securities and Exchange Commission (the "SEC") rules further defining key terms such as "swap" and "security-based swap" became effective and triggered the effectiveness of a number of other rules.
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