Around this time last year the Commodity Futures Trading Commission (“CFTC”) made major changes to Regulation 1.35(a) which will be taking effect on December 21, 2013. Perhaps the most widely discussed component of the CFTC’s recent amendments is the obligation of certain Futures Commission Merchants (“FCMs”), Registered Foreign Exchange Dealers (“RFEDs”) and Introducing Brokers (“IBs”) to tape record all oral communications concerning quotes, solicitations, bids, offers, instructions, trading, and prices that lead to the execution of a transaction in a commodity interest. The rule also includes an obligation to record oral communications related to cash or forward transactions (as defined…