On October 13, 2016, the Commodity Futures Trading Commission (“CFTC’”) unanimously issued an order establishing December 31, 2018 as the swap dealer de minimis threshold phase-in termination date (the “Order”). The Order is effective October 13, 2016.

Summary of the Order

Pursuant to CFTC Regulation 1.3(ggg), a person shall not be deemed to be a…