As spring approaches, small utilities are also facing new compliance deadlines for CFTC-regulated transactions, such as swaps and trade options. While it is always possible that the CFTC will extend the deadlines once more, as has happened in the past, experience suggests that any extensions will only come at the last minute. Accordingly, utility clients and friends should be planning now to be in compliance with new requirements, in order to continue to enter into these transactions and to avoid disruption of existing and ongoing transactions. The attached client alert gives a summary of compliance dates that may affect your utility.
If you have any questions, please contact Lisa Dowden or Melissa Birchard.