The CFTC also proposed transition rules designed to provide additional time for compliance with the clearing and trade execution requirements established under Dodd-Frank. Similarly to the transition rules for margin requirements and documentation requirements described above, implementation would be phased in according to the level of swap activity of a swap participant. As with the proposed rule described above, Category 1 would include swap dealers, security-based swap dealers, major swap participants, major security-based swap participants, and private funds executing over 20 swaps per month. Category 2 would include commodity pools, private funds executing less than 20 swaps per month, employee benefit plans, and persons predominantly engaged in certain banking or financial activities. The CFTC proposes that compliance with clearing requirements will be phased in as follows: (1) swap transactions between a Category 1 entity and another Category 1 entity, or another entity that desires to clear the swap transaction - within 90 days after the effective date set by the CFTC for mandatory clearing; (2) swap transactions between a Category 2 entity and a Category 1 entity, another Category 2 entity, or another entity that desires to clear the transaction - within 180 days; and (3) all other swap transactions that are not subject to the end-user exception - within 270 days. The trade execution requirements will be effective on the later of: (a) the applicable deadline for implementation of clearing requirements, and (b) 30 days after the swap is made available for trading. Comments to the proposed rule may be submitted on or before November 4, 2011. The text of the proposed rule is available by clicking here.