Over the next several days, we will issuing a series of postings on the joint SEC/CFTC rule proposal released on December 7th and available here.


The purpose of the December 7th proposal was to further define key terms under Title VII of Dodd-Frank: swap dealer, security-based swap dealer, major swap participant, major security-based swap participant, and eligible contract participant.

Comments are due in respect of the rule proposal 60 days after the date on which the proposal is published in the Federal Register. As of the date of this posting, the rule had not yet been published.


The purpose of our multi-part series will be to provide our readers with an applied summary of the rule proposal – nota bene – applied summary (not your grandma’s legal summary):

1) Applied: We will develop tools to help our readers apply the proposal to their business and, in so doing, determine whether or not a comment letter makes sense; and

2) Summary: Since our series is a summary, the material is a supplement to, rather than a substitute for reading the rule proposal.

Given the length of the rule proposal (179 pages single-sided, double spaced), we decided to prepare a multi-part series: too much of a good thing is a bad thing.

More to come soon.

Good afternoon. Good reading. TSR