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ARTICLE · 28 FEBRUARY 2013

Imminent Dodd-Frank Compliance Issues For Users Of Swaps And Derivatives

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The implementation of the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act affecting users of swaps and derivatives has been moving forward.

United StatesFinance and Banking
David Reicher
David Reicher
Kathryn Trkla
Kathryn Trkla
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Implementation of the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) affecting users of swaps and derivatives has been moving forward. Numerous rules of the Commodity Futures Trading Commission (CFTC) require compliance actions and changing business practices between now and early June 2013. For example:

  • If a borrower or issuer entered into an interest rate swap in connection with a loan or a bond issue prior to July 21, 2010, which expired (or remained in place) on or after July 21, 2010, it has recordkeeping responsibilities requiring compliance by April 10, 2013. Swaps done on or after July 21, 2010 have increasing levels of recordkeeping requirements.

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