Overview of Final Rules on Recordkeeping and Reporting of Swaps
This memorandum discusses the final rules adopted by the Commodity Futures Trading Commission governing recordkeeping and reporting of swaps. These regulations establish an extensive recordkeeping and reporting regime, which has significant implications for all swap counterparties, including end-users. Alongside record retention and retrievability requirements, the final rules create a dual framework for the periodic and real-time reporting of swap transaction data. This scheme implements section 727 of the Dodd-Frank Act, which requires all swaps, whether cleared or uncleared, to be reported to swap data repositories that will collect and maintain swap transaction data, making such information available to regulators and, to a lesser extent, the public.