On September 19, 2012, the CFTC approved an application by DTCC Data Repository, LLC (DTCC) for provisional registration as a swap data repository (SDR) under the Commodity Exchange Act. DTCC is the second entity (after ICE Trade Vault, LLC) to be granted registration status as an SDR. DTCC is now provisionally registered as an SDR for the following types of swaps:

The first phase of the three final major swap data reporting rules under Dodd-Frank technically becomes effective on October 12, 2012 and DTCC expects to be fully ready to operate on that date. However, PLC Finance has obtained information from the CFTC suggesting that, as a practical matter, the first swap data reporting compliance dates will not occur until January 1, 2013 (or the first day thereafter that SDRs accept swap data). This is because the first compliance dates specified in the final swap data reporting rules applies only to the credit and interest rate swaps of swap dealers (SDs) and major swap participants (MSPs) and the earliest date that SDs and MSPs are required to register as such with the CFTC is December 31, 2012. CFTC guidance to this effect is expected shortly. Real-time swap data reporting also cannot begin on October 12 because rules on large block trades that are granted limited exceptions from real-time swap data reporting have not yet been finalized.

For more information on the compliance dates for:

For more information on DTCC's registration as an SDR, see its press release.

To learn more about swap data reporting under Dodd-Frank, see Practice Note, The Dodd-Frank Act: Swap Data Reporting and Recordkeeping and Checklist, The Dodd-Frank Act: CFTC Swap Data Reporting Required Data Fields.

For an overview of swap regulation under Dodd-Frank, see Practice Note, Summary of the Dodd-Frank Act: Swaps and Derivatives.