On July 18th PwC hosted an industry roundtable to talk about Dodd-Frank “day two” compliance. More than 30 participants from 18 major swap dealers attended. The purpose of the event was to discuss issues, challenges and approaches to compliance with Dodd-Frank’s swap dealer rules.
In a 90 minute closed-door session, participants discussed the impact of the CFTC Cross-Border Guidance and Exemptive Order, the role of the chief compliance officer (CCO) function, swap dealer risk management, and diligent supervision requirements.
The agenda also featured a 90 minute session with Gary Barnett, Director of the Division of Swap Dealer and Intermediary Oversight at the Commodity Futures Trading Commission (“CFTC”). Mr. Barnett addressed key issues facing swap dealers as they build out their swap dealer compliance and risk management programs. He also provided his perspective on the importance of swap dealer governance structures, CCO reporting lines and insight into the CFTC’s expectations related to compliance and risk management.
Following Mr. Barnett’s remarks, participants also had the opportunity to ask him questions on a wide range of topics, including the role of the CFTC in upcoming regulatory examinations, the final cross border guidance, chief compliance officer reports, the meaning of “materiality” for reporting purposes, the ISDA protocols, telephone recording rules, the role of chief risk officers in swap dealer risk management programs, and the distinctions between supervision and compliance functions.