The Dodd-Frank Act of 2010 amended the definitions of FCM, IB, CPO and CTA to include “swaps.” On August 13, 2012, the CFTC published final rule definitions for “swaps”, “security-based swaps” and “security-based swap agreement”. Therefore, any IBs that are not currently registered but are acting as an IB with respect to swaps subject to the jurisdiction of the CFTC must file to be registered with the CFTC on or before December 31, 2012, and be approved as a swap designated IB Member of NFA. In addition, any person associated with a newly registering IB that engages in activities involving…