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SEC Adopts Recordkeeping and Reporting Rules for Security-Based Swaps  (Volume 53, Number 2– January 29, 2020)


Author:  Julian E. Hammar.


Source: Volume 53, Number 02, January 15 2020 , pp.13-24(12)




Review of Securities & Commodities Regulation

Abstract: 

The final rules rely heavily on the existing recordkeeping and reporting framework for broker-dealers, but with adjustments depending on the type of firm. The author discusses these provisions and then the rules as applied to various activities: record making; record preservation; periodic reporting and annual audit; early warning notification; and security counts. He closes with the provisions for alternative compliance with CFTC rules and substituted compliance for foreign dealers.

Keywords: Section 15F; Registration Status; Rules 17a-3-5, 11, 13, 18a-5-8; Record Preservation; Alternative Compliance with CFTC Rules

Affiliations:  1: FisherBroyles LLP.

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