For Swap Dealers (SD) and Major Swap Participants (MSP), Friday October 12, 2012 was the effective date for which compliance to the swap public and regulatory reporting rules of the Dodd-Frank Act is required (for interest rate and credit swaps). Many financial institutions have implemented solutions to support these requirements. We published a note (downloadable here) providing an overview of the technical complexities that a reporting solution would need to resolve. Some of these complexities emerge from the following:
We offer the following schematic of a reporting solution and use it to discuss these technical complexities further.
We conclude that SDs and MSPs should review the reporting solutions they have in place and with the help of carefully chosen use-cases test the correctness, end-to-end integration and latency of their implemented reporting solution, and benchmark these appropriately to an industry peer group.