Security-Based Swap Dealers: Gearing Up for Registration

This article first appeared in Compliance Reporter.

The Securities and Exchange Commission is slowly finalizing its rules under Title VII of the Dodd-Frank Act for the registration and regulation of security-based swap dealers (SBSDs). While a compliance date for SBSD registration has not yet been established, many firms are starting to consider implementation plans for the new regime. Meanwhile, a number of substantive requirements—such as trade reporting and margin for uncleared swaps effected by SBSDs that are banks—may not depend on firms being registered and will kick in even before that deadline.