Client Alert: CFTC Finalizes Recordkeeping Requirements for Certain Transactions

February 7, 2016

The Commodity Futures Trading Commission (“CFTC”) recently released  a final rule under which entities that are not registered or required to register with the CFTC as Swap Dealers, Major Swap Participants, brokers or other types of futures professionals, but that are members of designated contract markets (“DCM”) or swap execution facilities (“SEF”), are excluded from certain recordkeeping requirements.  The exclusion thus can assist commercial end-users of commodities that are also members of a DCM or SEF.  For your convenience, the attached memorandum briefly summarizes key points from this rule.

Please see the full Client Alert linked below for further details.