On August 5, 2015, the US Securities and Exchange Commission (“SEC”) took several incremental steps toward completing its regulatory framework for security-based swap dealers and majority security-based swap participants (“SBS Entities”). The SEC unanimously adopted final rules (the “Final Rules”) providing the registration process for SBS Entities, including the detailed forms that registrants will be required to file. The SEC also voted 3-2 to propose rules to establish a process for an SBS Entity to apply for permission to continue to have associated persons for security-based swap activity that are subject to statutory disqualification (the “Disqualification Waiver Process”).

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