The ABA seeks CFTC and SEC rulemaking, an interpretive letter, exemptive relief, or other guidance on the eligible contract participant (ECP) definition. As a result of Dodd-Frank Act rulemaking implementation effective October 12, 2012, only ECPs are able to enter into over-the-counter swaps. Banks need clarity on the ECP definition and it has a particular impact on small and medium-sized businesses. The CFTC issued a No-Action and Interpretation Letter on the implementation date.
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