Dodd-Frank provides for the comprehensive regula- tion of swaps and requires “swap dealers” and “major swap participants” to register with regulators. 3 As many private funds engage in various types of swaps and derivatives transactions, private fund managers will need to determine if their funds are captured by these new cat- egories, which would then require registration and com- pliance with numerous new compliance requirements. Since many of the rules and defi nitions have only been proposed and not fi nalized, however, it is not possible to make any fi nal determinations at this time
