Swaps

FINRA is uniquely qualified to provide the Commission with a familiar and consolidated platform for standalone SBSEs and bank SBSEs to file the FOCUS Report

The Commission proposes to exempt swaps entered into with a central bank, sovereign entity, or international financial institution from the Clearing Requirement

The IAA: The proposal remains vague and would leave advisers open “to second-guessing in hindsight"

The revised compliance schedule mitigates the potential of a market disruption

The Commission is also proposing revisions to streamline the requirements for reporting new swaps

These matters are currently the subject of relief in certain no-action letters from Commission staff

Rule includes an interpretation addressing the application of the portfolio reconciliation, portfolio compression, and trading relationship documentation requirements to cross-border security-based swap activities

The Commission is providing guidance regarding the application of certain uses of the terms ‘‘arranged’’ and ‘‘negotiated’’

The existing framework is largely a historical remnant of an approach that predates cash-settled futures contracts

The Commission is granting this nine-month extension because it believes the temporary exemptions from these provisions warrant further consideration