CFTC Proposes Updated Business Conduct and Documentation Rules for Swap Dealers

The CFTC has proposed rule amendments to codify no-action positions for swap dealers and major swap participants, harmonizing requirements with SEC and MSRB regulations.

The Commodity Futures Trading Commission (CFTC) has published a proposed rulemaking to revise business conduct and swap documentation requirements for swap dealers and major swap participants. The proposed amendments seek to formally codify existing CFTC no-action positions covering specific compliance and documentation obligations applicable to these registered entities. According to the regulator, adopting the proposed changes would further harmonize the CFTC's framework with standards established by the Securities and Exchange Commission (SEC) and the Municipal Securities Rulemaking Board (MSRB). The commission has opened a public consultation on the proposal, setting the deadline for public comments on or before October 24, 2025.