On August 27th, the CFTC decided to defer compliance dates with swap dealer external business conduct standards that involve documentation until January 1, 2013 (See pages 157 and 158 of the adopting release for the "Documentation/Compression" rule, which is available here)

Many of these business conduct standards were driving the Dodd-Frank Protocol and LEI initiatives.

The CFTC's action is likely to provide derivatives market participants with a slight reprieve (from mid-Q4 2012 to beginning Q1 2013) in terms of timing pressures related to compliance with the Dodd-Frank Protocol and obtaining LEIs (or "CICIs" as they are properly called).