Peace of mind in the quality of your DFA reporting
What is DFA?
The US Congress passed the Dodd Frank Act in response to the financial crisis and the subsequent G20 commitment to improving transparency and reducing risks in derivative markets. It is a wide-ranging package of obligations on firms based in US and in other jurisdictions relating to their internal and external business conduct, including reporting.
What do you have to report?
Firms trading derivatives must report details of swaps to the Commodities and Futures Commission (CFTC) and in the near future, to the Securities and Exchange Commission (SEC) via a Trade Repository. This includes the primary economic terms and any event that affects the valuations or terms of the contract (Part 45) to allow regulators monitor systemic risk. There is also an obligation on firms to report in real-time to provide transparency on pricing to the market. Like EMIR, DFA covers over-the-counter derivatives but unlike EMIR it excludes exchange-traded derivatives (ETDs).
A full suite of controls for DFA
Kaizen’s ReportShield quality assurance service will give you the ability to demonstrate appropriate control over your reporting obligations. Features of the service include:
- Accuracy testing of all DFA open positions at the Trade Repository
- Full governance structure, policy documentation, guidance and training for staff on the reporting obligation
- Completeness, validity and accuracy of reporting for part 43, 45 and 46
- Cross-regulation testing to ensure consistency with other regimes
- All client identifiers used are checked for appropriateness for the regulation and properly mapped
- Application of an advanced reconciliation between a primary trading system and the records held at the Trade Repository
- Validation that firms are classifying their clients and counterparties correctly in terms of US persons and regulatory status ie. swap dealer, non-swap dealer etc.
Ensure your DFA reporting is accurate and complete
Firms are increasingly being asked by the CFTC to evidence effective, comprehensive controls mapped back to the obligations.
Contact us to discuss your DFA reporting challenges and find out how we can give you peace of mind in the integrity of your reporting.