After almost two years since the Dodd-Frank Act (DFA) was put on the statute books, the first swap-related articles finally take effect on 12th October this year. Now everyone can be assured they are trading, clearing and reporting under a common set of rules, right?
Not so. While DFA requires market participants to report OTC trades to Swap Data Repositories (SDR) and introduces conduct business rules, other jurisdictions have not yet finalised their respective regulations. A regulatory conundru