CFTC Adopts Swap Clearing Documentation, Timing and Risk Management Rules
Client Memorandum

Created date


On March 20, 2012, the CFTC finalized a package of rules related to swap clearing.  The rules set standards for:

  • the arrangements that swap dealers (“SDs”), major swap participants (together with swap dealers, “Swap Entities”) and futures commission merchants (“FCMs”) that clear swaps for customers and derivatives clearing organizations (“DCOs”) have with respect to clearing customers;
  • timing of acceptance or rejection of trades for clearing by DCOs and clearing members that are FCMs or Swap Entities (“Clearing Members”);
  • risk management procedures of Clearing Members; and
  • swap processing.