Swap alert. Historical data matters. Reporting of Swap transactions is an essential part of compliance.

According to regulations outlined by the Commodity Futures Trading Commission (CFTC): Any firm that does over $8 billion in over-the-counter (OTC) trading must register as a Swap dealer and they must maintain records for any Swap transactions that have occurred —  not just those since the enactment of Dodd-Frank, but prior to the Act as well. Moreover, those records must be in exactly the form that they existed at the time they were created.

Sound familiar? So, what’s required?[spacer height=”20px”]

• SDR Reporting – Targets Swap counterparties and requires them to report detailed information to a Swap data repository registered with the CTFC for the life of the Swap transaction. While publicly noted, complete details are available only to the CFTC.

• Real-time Reporting – The SDR distributes information about Swaps, which is available to the public. Currently, this type of reporting can be delayed if a large block of transactions takes place.

• Past Swap Reporting – Details of past Swap transactions determined by the date the Swap was entered into and completed. Requires some information concerning any Swap transaction conducted during or after July 2010.

• Compliance – As Swap dealers increasingly turn to third-parties to meet their archiving requirements, it is critical to provide a letter of intent to regulators. A system configuration plan must be put in place for records access and systems must be regularly tested and updated as needed.

Complying is an undertaking without end. Want more time to do your real work, and keep your CFO happy? Let’s talk. Ask about Patrina’s comprehensive compliance solutions specifically designed for SDs, Broker/Dealers, RIAs, and FCMs. Or…you could spend your time doing it all yourself…