Dodd-Frank Swap Reporting Update

The CFTC and the SEC have released rules that will require swap parties to report all security-based and all other swap transactions entered into before July 21, 2010, and that have not expired as of that date.

Both the U.S. Commodity Futures Trading Commission (CFTC) and the U.S. Securities and Exchange Commission (SEC) have released rules that will require swap parties to report all security-based and all other swap transactions entered into before July 21, 2010, and which have not expired as of that date (pre-enactment unexpired swaps). Under the new rules, parties to pre-enactment unexpired swaps will need to file reports with a registered security-based swap data repository (for security-based swaps) or a registered swap data repository (for all other swaps) within 60 days after the repository is registered, or by the compliance dates to be established by the SEC and the CFTC.