Friday may be hockey night in Canada, but this Friday, October
31, 2014, is also the deadline for end users that trade
over-the-counter (OTC) derivatives to deliver certain information
and agreements to their Canadian dealers to comply with Canadian
reporting requirements. To provide the necessary information and
agreements to Canadian dealers, the International Swaps and
Derivatives Association (ISDA) has developed a Canadian
representation letter. Failure to deliver the Canadian
representation letter by Friday, October 31, is more than a
five-minute major penalty; it may prevent swaps end users and other
counterparties from trading with Canadian dealers after the
deadline.
On November 14, 2013, the Ontario Securities Commission,
Québec Autorité des marchés financiers and
Manitoba Securities Commission collectively published rules for
product determination, trade repositories and derivatives data
reporting (the Canadian reporting rules). The Canadian
