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 a webinar available on its site to address the above issues. The webinar covers:
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
ISDA has also published a standard form of confirmation for a market agreed coupon contract as an additional choice for market participants who wish to use over-the-counter interest rate swaps that have common, pre-agreed terms.
Check dodd-frank.com frequently for updated information on the JOBS Act, the Dodd-Frank Act and other important securities law matters.