The CFTC has adopted two final rules - a Swap Data Reporting Rule and a Real-Time Reporting Rule - that, in less than a fully coordinated manner, establish the new Dodd-Frank Act reporting regime for swaps. The rules require market participants to report a host of swap information upon execution or shortly thereafter to a swap data repository (“SDR”), which is then responsible for disseminating a portion of that information to the public. Updated information for a given swap must be reported to the same SDR throughout the life of the swap.

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