Law360, New York ( February 5, 2015, 11:22 AM EST) -- It has been almost five years since Congress enacted the Dodd-Frank Act which provided the U.S. Commodity Futures Trading Commission with oversight over the vast majority of the over-the-counter swaps market. The CFTC, which also has jurisdiction over other derivatives, such as futures and options, has spent that time and significant resources promulgating rules and issuing staff interpretations and no-action relief to implement Dodd-Frank's new requirements. The result is a patchwork of rules and guidance that has had significant direct and indirect effects on the ways energy market participants engage in physical commodity transactions and hedge their risks using derivatives....