Swap Data Regulation - Comment Letter - Depository Trust & Clearing Corporation - February 7, 2011

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Dodd-Frank Timeline, Real Time Public Reporting of Swap Transaction and Pricing Data
Final Rule Issue Effective Date Compliance Date
December 20, 2011 March 9, 2012 December 31, 2012

Real Time Public Reporting of Swap Transaction and Pricing Data
February 7, 2011

Summary points from the comment letter:

  • "DTCC urges the Commission and the Securities and Exchange Commission (“SEC”) to harmonize their respective regulatory regimes establishing reporting processes for credit and equity derivatives."
  • "The Commission should set and apply consistent thresholds for block trades in public dissemination by both SDRs and any market operators who directly disseminate information."
  • "DTCC questions whether an unregulated entity should be fulfilling the Commission’s dissemination requirements, when SDRs are created by the statute to collect the very same data for regulatory and reporting purposes."
  • "After the final rules are adopted, market participants must be given adequate time to develop and implement appropriate reporting and compliance systems and procedures."


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