Originally, several provisions under Dodd-Frank con- cerning swaps would have taken effect on July 16, 2011, but since such provisions required the SEC and CFTC to implement fi nal rules, that date was not achievable. 6 The effective date of most provisions was consequently delayed until December 31, 2011 or until new rules be- come effective, if earlier. 7 Importantly, any provision that references “swap,” “security-based swap,” “swap dealer,” and “major swap participant” is delayed because these defi nitions have not yet been fi nalized. 8 Once fi nalized, these provisions will set forth most of Dodd-Frank’s most stringent operating requirements. .
