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March 07, 2012
Brattle Principal Romkaew Broehm Co-Authors Oil & Gas Monitor Article on Dodd-Frank Compliance

Brattle principal Romkaew Broehm has co-authored an article for Oil & Gas Monitor discussing the impact of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd Frank) on compliance issues for oil and gas companies.

Co-authored by Julia Sullivan of Akin Gump Strauss Hauer & Feld LLP and Cary Oswald of Xcel Energy, the article provides insight into Dodd Frank, which will serve to improve transparency among energy trading activities. The regulation, however, will impose considerable regulatory burdens on market participants and could significantly affect how oil and gas companies manage their trading operations and business risk. All market participants are potentially subject to significant new regulations regarding credit, collateral, capital structure, and other matters, but the most significant burden will fall on swap deals and major swap participants.

The authors also detail the timeline of Dodd Frank’s implementation, which will occur in several phases as outlined by the Commodity Futures Trading Commission (CFTC). The initial phase will include comprehensive reporting and data collection requirements, which will demand substantial compliance activity in the beginning of 2012 to meet the expected deadline of mid-2012. The authors conclude that energy companies should begin mapping a Dodd Frank compliance plan immediately in order to ensure effective implementation of the new regulation.

To read the complete article, please visit the Oil & Gas Monitor website.