Key takeaways:

• The Commodity Futures Trading Commission has recently adopted final rules to implement:
  • the prohibition of certain terms in the documentation between a customer and a futures commission merchant that clears trades on behalf of the customer;
  • the timing of acceptance and rejection of trades for clearing by a derivatives clearing organization and its clearing members; and
  • certain risk management procedures of futures commission merchants, swap dealers and major swap participants that are also clearing members.
• In general, these rules will become effective on October 1, 2012.