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)
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.