The transition to registered swap dealer status for OTC market participants will require a thorough review of current booking entities and business practices.
This in turn will drive a complex analysis of — and changes to — systems, policies and procedures.
There may be insufficient time after issuance of final registration rules, to effect the necessary changes to bring the business into compliance.
Firms should act on these challenges now, instead of waiting until “regulatory certainty” emerges, to avoid putting at risk their franchises and reputations.
This FS Viewpoint identifies several of the pressing and complex issues that prospective swap dealers will have to confront and resolve in order to become registered and remain in compliance. It also provides insight into how industry participants are dealing with these issues and proposes a framework for response.