A Herculean effort is underway to implement the myriad regulatory changes mandated or authorized by passage of the Dodd-Frank Wall Street Transparency and Accountability Act of 2010 (Act), as Federal regulators feverishly work to develop the numerous rules and regulations within required time periods. Recognizing the enormity of the rulemaking task before them, both the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) have requested comments on various rules to be promulgated under Title VII of the Act, even before the rules have been drafted or published for public comment. These requests for comment provide derivatives market participants an excellent opportunity to constructively participate in the rulemaking process at its earliest stages.

Once enacted, these rules will govern the oversight of previously unregulated over-the-counter derivatives transactions and will address all aspects of the regulatory oversight brought on by the Act, including new clearing, exchange trading, position limits, and reporting requirements. A list of the specific rules and studies called for in Title VII of the Act is attached here.

In order to expedite the receipt and review of comments on these rules, the CFTC and SEC have posted on their respective Web sites specific topics for which they are currently requesting comments. A list of the topics for which each regulator has requested comments is available here. Comments may be submitted electronically on both the CFTC and SEC Web sites, at the internet pages linked below:

Web site for comments to the CFTC (here) Web site for comments to the SEC (here)