Unclear on substituted compliance

direction2013

A pattern has emerged in the Dodd-Frank rule-making process. The Commodity Futures Trading Commission (CFTC) issues a rule and sets a deadline, but within hours of the rule taking effect – and sometimes after – it releases a no-action letter delaying the start date. That happened again last month, when a crucial exemption order governing how cross-border trades should be treated was extended on July 12 – the day it was due to expire – alongside the release of the final