Dodd-Frank subjects the over-the-counter derivatives market in energy and other commodities to an expansive new regulatory regime to be placed under the jurisdiction of the Commodity Futures Trading Commission.

Energy traders now face new capital and margin requirements, reporting and recordkeeping obligations, and position limits with respect to energy contracts that they formerly traded virtually free from regulatory restrictions. The CFTC will be implementing the new regulatory requirements through an expansive program of 60 new rulemakings.

Leonard, Street and Deinard will be closely monitoring the CFTC rulemaking and implementation process and is available to update our clients and business relationships on important compliance requirements as they develop.