Key Takeaways 

• The CFTC adopted interim final rules deferring the compliance dates (until either May 1, 2013 or July 1, 2013) for the majority of external and internal business conduct rules for swap dealers (SDs) and major swap participants (MSPs), which were initially set from December 11, 2012 through March 11, 2013. 
• All market participants will be subject to the new compliance dates regardless of their adherence to the ISDA August 2012 DF Protocol (or similar protocol) or their execution of bilateral amendments of their existing relationship documents with their SD or MSP counterparties. 
• As the compliance dates for all other external and internal business conduct rules remain unchanged, SDs and MSPs must still commence compliance with those regulations on their original compliance dates.