Reval: Another Common Sense Win For End Users Under Dodd-Frank

Better late than never. Last week the CFTC provided a no-action letter recommending that the Commission does not enforce the requirement for inter-affiliate swap reporting under Part 45 governing Swap Data Repository (SDR) rules.  Under these rules, a non-financial corporate that centralizes its hedging activity by consolidating its group needs into a larger dealer-facing swap is still required to report the subsequent back-to-back intra-group trades to an SDR.  Opponents of this rule felt

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