Swap Data Regulation - White Papers

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Dodd-Frank Timeline, Swap Data Recordkeeping and Reporting Requirements
Final Rule Issue Effective Date No-Action Relief, Part 43/45 No-Action Relief, Part 23
January 13, 2012 March 13, 2012 July 1, 2013 (IRS, CDS); Aug. 19 for other swaps June 30, 2013
Dodd-Frank Timeline, Swap Data Recordkeeping and Reporting Requirements for Pre-Enactment and Transition Swaps
Final Rule Issue Effective Date Compliance Date
June 12, 2012 August 13, 2012 April 10, 2013

White papers, consultations, and other research addressing swap data.

CPSS/IOSCO: Report on OTC Derivatives Data Reporting and Aggregation Requirements - August 24, 2011

August 24, 2011

Recommendations from the task force:

  • Minimum data reporting requirements, including transaction economics, counterparty information, underlier information, operational data and event data;
  • Access to data, for entities such as market regulators, central banks, prudential supervisors and resolution authorities;
  • Methodology and mechanism for aggregation of data to include "Legal Entity Identifiers" ("LEIs");
  • International LEI development and principles to be determined and harmonized by regulators and industry participants; and
  • Development of a standard international product classification system.
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CFTC/SEC: Joint Study on the Feasibility of Mandating Algorithmic Descriptions for Derivatives - April 7, 2011

April 7, 2011

One of the mandates of the Dodd-Frank Act was a requirement that the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) jointly study the feasibility and logistics of adopting standardized, computer-readable algorithmic descriptions to describe complex financial derivatives, and whether these descriptions, combined with "standardized legal definitions, may serve as the binding legal definition of derivative contracts."[1]

Staff concluded that the industry is capable of adapting a common set of computer-readable descriptions, including unique entity and product identifiers, but that, prior to the adoption of regulations, the industry must agree to standards and a cost-benefit analysis should be conducted.

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  1. CFTC-SEC delivers report on mandating algorithmic description for derivatives. CommodityOnline. Retrieved on April 11, 2011.

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