Important Clarification of the Swaps Push-Out Effective Date: Federal Banking Agencies Clarify that the Effective Date of the Swaps Push-Out Provision is July 16, 2013

Sullivan & Cromwell LLP - March 30, 2012

On Friday, March 30, 2012, the federal banking agencies jointly issued guidance clarifying that the effective date of Section 716 (the swaps push-out provision) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) is July 16, 2013. This guidance affirms that the effective date of Section 716 is two years from the effective date of Title VII of Dodd-Frank, which is the Wall Street Transparency and Accountability Act of 2010, rather than two years from the earlier effective date of Dodd-Frank. The guidance, therefore, provides needed clarification and resolves the uncertainty that had existed as to the effective date.