Dodd-Frank 30 Day Countdown: Day 23
Insights 
Robin Powers · June 23, 2011
SEC Provides Guidance and Temporary Relief Regarding Security-Based Swap Provisions of Dodd-Frank Act
The SEC today issued guidance as to whichTitle VII requirements will apply to security-based swap transactions when Dodd-Frank goes into effect. It also granted temporary relief to market participants from compliance with most of the new Exchange Act requirements that would otherwise apply on July 16th.
In addition, the Commission’s action provides temporary relief from Section 29(b), which generally provides that contracts made in violation of any provision of the Exchange Act shall be void as to the rights of any person who is in violation of the provision. This relief is expected to enhance the legal certainty provided to market participants.
Although the guidance and temporary relief are now in effect, the Commission is seeking input from the public on today’s actions. Public comments should be received by July 6, 2011.
