On June 11, 2012, the Securities and Exchange Commission issued a policy statement describing the phase in of final rules regulating security-based swaps and security-based swap market participants.  The policy statement covers final rules to be adopted by the SEC under Title VII of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act, which establishes a comprehensive framework to regulate over-the-counter derivatives and authorizes the Commodity Futures Trading Commission to regulate “swaps” and the SEC to regulate “security-based swaps.”  The SEC is seeking public comment on its plan to phase in the final rules regulating security-based swaps and security-based swap market participants.