The CFTC settled enforcement cases against six swap dealers
that all involved reporting failures. In addition to the reporting
failures, the CFTC charged (i) one of the six dealers with failure
to supervise and (ii) another of the six dealers with risk
management deficiencies.
The reporting violations covered a variety of issues, including
(i) failure to properly report data, (ii) failure to report certain
transactions, (iii) failure to report legacy swaps and (iv) large
trader reporting violations.
The CFTC alleged that the swap dealer charged with violating
Rule 23.600 ("Risk Management") did not (i) designate a
governing body for purposes of designation as "senior
management" under the rule or (ii) have risk management
procedures or risk-tolerance limits separately considered by
appropriate senior management.
