CFTC Re-Proposes Capital Rules for Non-Bank Swap Dealers

January 20, 2017

The Commodity Futures Trading Commission has re-proposed capital, liquidity and financial recordkeeping and reporting rules for swap dealers and major swap participants that are not subject to capital rules of a Prudential Regulator.

The proposed rule also would amend the CFTC’s capital rules for futures commission merchants, including to address swap dealers dually registered as futures commission merchants.

In our memo, we provide an overview of the proposed rule and summarize the key issues that it raises. Comments on the proposed rule are due by March 16, 2017.