On September 10th, the CFTC issued orders permitting exempt commercial markets ("ECMs") and exempt boards of trade ("EBOTs") to continue to operate as ECMs or EBOTS temporarily after the deletion of the ECM- and EBOT-enabling provisions from the Commodity Exchange Act by the Dodd-Frank Act. The CFTC anticipates that many entities that currently operate as ECMs or EBOTs will seek to become either swap execution facilities ("SEFs") or designated contract markets ("DCMs") when the CFTC adopts regulations implementing the Dodd-Frank Act's requirements for those facilities. To facilitate the transition of current ECM and EBOT businesses to the new regulatory regime, the Commission determined that it is appropriate to provide grandfather relief to certain ECMs and EBOTs to temporarily continue their ECM and EBOT operations after July 15, 2011. The two orders set forth various conditions for receiving grandfather relief, including the filing of both a relief petition and a SEF or DCM application with the CFTC. The orders are effective immediately. CFTC Release No. PR5891-10.