This Legal Alert provides an overview of the status of significant rulemaking developments since the enactment of the landmark Dodd-Frank Wall Street Reform and Consumer Protection Act (D-F Act) this past summer, with a focus on those rules that will have an impact on end-users of derivatives. This paper addresses some of the important issues facing end-users and notes where the proposed rules would affect the derivatives activities of financial entity end-users and commercial entity end-users differently. As used herein, financial entities consist of entities that are not themselves swap dealers but are engaged in activities such as banking, insurance, or investing (e.g., insurers, hedge funds, mutual funds, commodity exchange-traded funds, energy traders and other investment entities). Commercial entities include manufacturers, energy firms, utilities, consumer products companies and service providers.1

Significant rulemaking developments impacting end-users are addressed below along with questions raised by the proposals...