Swap Data Regulation - Comment Letter - Goldman Sachs - January 18, 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
Dodd-Frank Timeline, Real Time Public Reporting of Swap Transaction and Pricing Data, SEC
Proposal Date Reopened Comment Period Deadline Final Rule Approved
December 2, 2010 July 22, 2013 January 14, 2015

Real Time Public Reporting of Swap Transaction and Pricing Data
Reporting and Dissemination of Security-Based Swap Information
January 18, 2011

Regarding the real-time reporting requirements from the comment letter:

"...we respectfully recommend that the Commissions modify the proposal in the following ways:"

  • "Define specific categories to reflect market differences within an asset class."
  • "Refine block thresholds to more accurately capture trades that would have a market inpact."
  • "Establish a tiered approach to the treatment for block trades."

"Further, we would suggest that the SEC reconsider the exclusion of certain equity swaps from the block trade regime."

References

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