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March 21, 2013
Are you Ready for May 1?
Complying with the CFTC’s External Business Conduct Rules
Replay the webinar Download the slides (PDF)
By May 1, all counterparties must have provided their registered Swap Dealers with legal classifications and representations to allow the Swap Dealers to comply with the CFTC’s External Business Conduct Rule (EBCR). After the EBCR deadline, Swap Dealers will only continue offering and executing swaps with in-scope counterparties who have provided the necessary information for compliance.
ISDA has developed a standard documentation solution to ease some of the operational burdens of the process, and has partnered with Markit to provide an online tool for compliance. Broadly speaking, there are three steps to compliance which will be discussed during the webinar.
- Applying for a CICI number from DTCC
- Adhering to the August 2012 D-F Protocol through ISDA’s Protocol Management website
- Completing the client questionnaire either via the ISDA Amend utility or another delivery mechanism
Katherine Darras, General Counsel, Americas, ISDA
David Moss, Partner, Purrington Moody Weil LLP
Lauren Teigland-Hunt, Managing Partner at Teigland-Hunt LLP
May 1 is approaching quickly. Register for this webinar, and learn what your firm needs to do now to continue trading after that date.
December 18, 2012
Extension of compliance dates:
The CFTC provided interim final rules for swap dealers and major swap participants, extending the compliance date for various External Business Conduct provisions covered by the ISDA August D-F Protocol from January 1, 2013 until May 1, 2013. In addition, the interim final rules extend until July 1, 2013 the compliance dates for Commission regulations related to portfolio reconciliation and swap trading relationship documentation (documentation changes required by these rules will be contained in a second, soon to be published ISDA protocol). We encourage market participants to adhere to the ISDA August D-F Protocol and provide questionnaires to counterparties well in advance of the May 1 compliance deadline.
ISDA August 2012 Dodd-Frank Protocol
ISDA Amend in partnership with Markit
ISDA Amend, a joint service provided by Markit and ISDA, enables swap dealers and their clients to amend multiple ISDA Master Agreements easily and efficiently with a single online tool. All aspects of the questionnaire are now available online. Visit Markit's ISDA Amend webpage.
Get started with ISDA Amend on Markit’s sign-up page: http://www.markit.com/mcpm-sign-up
DTCC CICI Utility Portal
Dodd-Frank Documentation Initiative webinars
Dodd-Frank Initiative documents: