February 20, 2020

The SEC Publishes their Dodd Frank Rules – Does Your Firm Trade Security Based Swaps?

Did you know that the SEC have now published their rules to implement Dodd Frank? Yeah – I know, a late bloomer.

John Philpott has written an excellent post alerting us all to the publication (on the 4th of February) of the SEC's rules to implement Dodd Frank for Security Based Swaps:

(I) an index that is a narrow-based security index;
(II) a single security or loan; or
(III) an event relating to a single issuer of a security or the issuers of securities in a narrow-based security index.

In plainer English to you and me, that’s things like security indices with nine or fewer component securities, single name swaps, single name CDS and TRS on a single security or loan.

John explains:

  • The time period for the 24 or so banks who will need to demonstrate compliance with these new rules
  • The need for regulatory experts to revisit their knowledge of US regulation
  • Trying to make your way through the arcane format of the federal register to understand the actual rules
  • The thousands of pages of text involved
  • The poor quality of the SEC website
  • Comparing the CFTC and SEC rules where they should be equivalent
  • Whether firms have the necessary people to begin these compliance projects
  • The short time period to get this done

For the full briefing please head over to John's website here.


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