Key takeaways

• Certain derivatives regulations adopted pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act will affect derivatives end-users. While the Commodity Futures Trading Commission (the "CFTC") has finalized most of its regulations, the Securities and Exchange Commission (the "SEC") has not finalized a number of implementing regulations applicable to security-based swaps.
• This client update sets forth a checklist of the actions to be taken by derivatives end-users to satisfy the currently applicable CFTC regulations.
• We continue to monitor this regulatory area and will update you as the CFTC and the SEC adopt further regulations that affect derivatives end-users.