Last month, the Commodity Futures Trading Commission (CFTC) approved for publication two proposed rules to amend existing regulations addressing cybersecurity.  The proposed rules would establish testing requirements for the automated systems used by designated contract markets (DCMs), swap execution facilities (SEFs), swap data repositories (SDRs), and derivatives clearing organizations (DCOs).  In particular, the proposed rules would require DCMs, SEFs, SDRs, and DCOs to conduct five types of cyber testing:  (1) vulnerability testing; (2) penetration testing; (3) controls testing; (4) security incident response testing; and (5) enterprise technological risk assessment.  The proposed rules also would establish minimum testing frequencies and independent contractor testing requirements for DCOs, SDRs, and covered DCMs (i.e., those whose total annual trading volume is five percent or more of the total annual trading volume of DCMs regulated by the CFTC for the year in question).