The SEC's Security-Based Swap Recordkeeping And Reporting Rules

On September 19, 2019, the Securities and Exchange Commission (SEC or Commission) adopted new rules and amendments establishing recordkeeping and reporting requirements for security-based swap dealers (SBSDs), major security-based swap participants (MSBSPs) and broker-dealers.¹ Although the rules become effective on February 14, 2020, the "compliance date" is tied to the date when SBSDs and MSBSPs must register with the SEC (i.e., October 6, 2021).²

Market participants should review the new rule requirements to assess whether improvements in technology are required to meet minimum standards for recordkeeping and reporting. SBSDs and MSBSPs that do not have the technology to store and maintain the information required by the new rules and rule amendments may need to invest in new systems and technology.