I. Introduction
The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) has long regulated commodity futures, options and forwards, and, since 2009, over-the-counter foreign currency and options transactions. In 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act substantially expanded the CFTC’s jurisdictional reach by adding comprehensive regulation of the swaps markets, including requiring the registration of Swaps Dealers and Major Swap Participants, requiring that certain swaps only be traded on electronic platforms known as Swap Execution Facilities, and imposing other transaction-level requirements concerning swap reporting and clearing. Thus, the CFTC’s current stated mission is to “protect market participants ...