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3/15/13 - Registered Swap Dealers and Major Swap Participants Ask: Now What?

The big push to register under Title VII of the Dodd-Frank Act is over. The December 31 deadline for the largest swap dealers has come and gone, as has the initial February 28 deadline for major swap participants. Chief compliance officers by now have taken their deep breaths, but the real challenge lies ahead. As one recently asked us: What do we do now? The big challenge they face is to make sure their firms are actually doing the things they’ve promised in registration documents. Considering that the chief compliance officer must report annually to the board of directors and certify compliance to the Commodity Futures Trading Commission — under criminal liability no less — the consequences are substantial.

Please click below to read a Sightlines InFocus by Douglas E. Harris and DJ Hennes, “Registered Swap Dealers and Major Swap Participants Ask: Now What?” They demonstrate how time-tested compliance methods, including the three-lines-of-defense controls framework, are still effective in helping firms tackle the new requirements under Title VII of the Dodd-Frank Act.