For any of you veteran Dodd Frankers out there – drum roll! – the SEC have just published their Final Rules for the ‘Cross-Border Application of Certain Security-Based Swap Requirements’ in the Federal Register.
Five years or so ago everyone would have been all over this but I wouldn’t be surprised now if folks have completely forgotten this was ever coming and that one day they might need to register to be a Security-Based Swap Dealer and so let me explain.
Wind back the clock to 2010 when the Dodd Frank Act was signed into legislation (yes, it really was that long ago) and you may recall that Dodd Frank divides regulatory authority of swap reform between the CFTC and the SEC – unhelpfully, there is no one-stop-shop like there largely is with ESMA and EMIR. Continue reading →
When I showed this blog to a chum of mine at another bank, he said my blogging’s now becoming like a London bus – you get nothing for two years and then two come along at the same time. He’s got a point! 🙂
Apparently it’s called ‘bus bunching’…
Anyway, I want to look at regulatory trade and transaction reporting and given we’ve just gone live with five brand new reporting regimes courtesy of MiFID 2, as well as the complete rewrite of EMIR trade reporting back in November last year, I really should have tried harder with my timing on this one because the ideas behind this blog were originally kicked around back in 2014 when I was at Barclays and I worked on the “what does good look like” for EMIR trade reporting first time round. Still, like a bus, better late than never and you’ll still be in good time to apply any findings ahead of SFTR and the CFTC’s rewrite of their Part 45! Continue reading →