On September 10th, CFTC staff provided guidance on when firms will be required to register as swap dealers. Presented in the form of questions and answers, the guidance advises that the swap dealer registration regulations will go into effect on October 12, 2012. Entities having more than $8 billion in swap dealing (the initial de minimis level) following that date must register by no later than two months after the end of the month in which they surpass the de minimis level. Most swap dealers must therefore register by December 31, 2012. The guidance also summarizes which regulations are relevant to determining when a person comes within the definition of the term "swap dealer;" which swaps are relevant to determining if a person is within the definition of swap dealer; to whom CFTC regulation § 1.3(ggg)(4)(iii) applies; and the regulations relevant to determining when a person is required to apply to be registered as a swap dealer. CFTC Guidance.