Final Rules on Recordkeeping and Reporting for Swaps

June 1, 2012

This is an alert which is part of a series of occasional memos about CFTC rules on “swaps” that may affect our utility clients.  While the CFTC has yet to issue a final definition of “swap,” it has finalized rules on your reporting and recordkeeping obligations with regard to swaps once it has been determined what they are.