On May 20th, Reuters reported that dealers in over-the-counter ("OTC") derivatives face a regulatory twilight zone on July 16, 2011. The Dodd-Frank Act repealed, effective July 16, 2011, the provisions of the Commodity Futures Modernization Act of 2000 that exempted OTC derivatives from being considered illegal futures and gave the CFTC explicit authority to regulate OTC derivatives. The CFTC, however, will not be able to implement its rulemaking authority by July 16, 2011. Twilight Zone.