Dodd-Frank Reporting

The Dodd Frank Act (DFA) is aimed at improving transparency and reducing risks in derivative markets. It is a wide-ranging package of obligations on firms based in the US and in other jurisdictions relating to their internal and external business conduct, including reporting.

What is DFA Reporting?

Firms trading OTC derivatives in the US must report details to a registered Swap Data Repository (SDR). The reporting obligations include;

  • Part 43 real-time reporting to provide transparency on pricing to the market
  • Part 45 transaction and valuation reporting to allow regulators to monitor for systemic risk.

The Securities Exchange Commission (SEC) oversee the reporting of OTC derivatives related to ‘single name’ Credit and Equity securities under the Security Based Swap Reporting (SBSR) portion of the DFA.

The Commodities and Futures Commission (CFTC) oversees the remainder of the reporting which includes all other OTC derivatives for Credit, Equity, FX, Interest Rates and Commodities asset classes. CFTC reporting commenced in 2013 with DTCC, CME and ICE operating SDRs. The CFTC is also implementing a substantial revision of the reporting rules, known as the CFTC ReWrite, and reporting under the new rules is due to commence in May 2022.

SEC SBSR reporting was originally expected to begin around 2016 but was delayed and is due to commence in November 2021.

How we can help

Our ReportShield™ quality assurance services give you the ability to demonstrate appropriate controls over your reporting obligations for Parts 43, 45 and 46. We can also conduct cross-regulation testing to ensure consistency with other regimes and provide remediation of reports.

What DFA reporting challenges are you facing?

For a conversation with one of our regulatory specialists, please get in touch.

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