Client Alert: CFTC Compliance Update

April 1, 2013

Two CFTC compliance deadlines came and went during the past few weeks, and on each of them, the CFTC waited right up to the deadline to issue various forms of relief.  You may have seen trade press accounts of the exemptions for governmental and cooperative utilities and RTO/ISO transactions.  Additionally, no-action letters gave more time to comply with and reduced certain reporting and recordkeeping requirements.  The attached client alert gives a summary of the recent CFTC issuances.  Please feel free to contact Lisa Dowden or Melissa Birchard with any questions.