On December 18, 2019, the Securities and Exchange Commission
(“SEC”), as part of supplemental
guidance and rule amendments addressing the cross-border
application of certain rules regulating security-based swaps
(“SBS”) pursuant to Title VII of the
Dodd-Frank Act (the “Final Rule”),1 issued
a statement regarding compliance with rules for SBS data
repositories (“SDRs”) and Regulation
SBSR (the “Statement”).
Please click here to read the alert memorandum
regarding the rest of the Final Rule.
The Statement provides certain time-limited relief from
compliance with certain provisions of Regulation SBSR as well as
certain SDR rules. The SEC adopted this relief in light of
efforts to increase harmonization of its SBS reporting rules with
the swap reporting rules of the Commodity Futures Trading
Commission (“CFTC”), the CFTC’s
announced reconsideration of its swap reporting rules,2 and
concerns that dissimilar rules between the CFTC’s and
SEC’s regimes would require
