Sutherland Alert: Chairman Gensler Outlines Timeline for Finalizing and Implementing the Commodity Futures Trading Commission’s Dodd-Frank Rulemakings March 18, 2011

Sutherland Alert: Chairman Gensler Outlines Timeline for Finalizing and Implementing the Commodity Futures Trading Commission’s Dodd-Frank Rulemakings March 18, 2011

by Jamie Cain

In a speech (a copy of which can be found here) at the recent Futures Industry Association (FIA) conference held in Boca Raton, Florida, earlier this week, Commodity Futures Trading Commission (CFTC) Chairman Gary Gensler laid out his new "best case" plan for proposing the remaining rules to be promulgated by the CFTC under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and then finalizing all of the CFTC's Dodd-Frank rulemakings. An outline of Chairman Gensler's plan can be found here.

Under Chairman Gensler's best case scenario, the CFTC will issue all except one1 of its proposed rules by the end of April 2011 and will finalize its rules in three phases between the Spring of 2011 and the Fall of 2011. Chairman Gensler also acknowledged concerns regarding the need to sequence and delay the effective dates of the CFTC's final rules to allow market participants time to prepare for, and adopt to, the new requirements imposed by the rules. Chairman Gensler's new plan is a departure from his original goal of actually finalizing all of the CFTC's Dodd-Frank rulemakings during the first half of 2011.

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