On September 17th, Reuters noted that the CFTC guidance on when firms will be required to register as swap dealers still leaves unanswered the extent to which foreign exchange derivatives will be counted towards the de minimis trading level which triggers the registration requirement. Unanswered Questions. On September 19th, Bloomberg reported an industry group representing agricultural and energy firms has written the CFTC asking that the October 12, 2012 effective date for the swap dealer registration rules be delayed since the agency has yet to complete capital and collateral rules for registered entities. Delay.