The club no-one wants to join: swap dealer rules remain unclear

Around 120 firms will be classed as swap dealers under the Dodd-Frank Act, US regulators estimate – but hundreds more will be uncertain whether they are caught or not. Answering that question may not be easy, lawyers warn. Peter Madigan reports

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Gary DeWaal

According to some estimates, there are around 1,500 separate regulatory requirements that apply to swap dealers under the various Dodd-Frank Act rules – ranging from clearing and reporting mandates, to a ban on making political donations to state or government entities if a dealer also trades with them. But it wasn’t until April 18 that US regulators agreed a final definition of the term. Some entities – the big over-the-counter market-makers – long ago accepted they would be caught.

“I think it

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