Reporting and Recordkeeping for Swaps and Derivatives
The Commodities Futures and
Trading Commission (CFTC)
requires that swap dealers
and major swap participants
implement significant policies
and procedures to mitigate
the risks associated with
trade violations and that
records of any swap should
be kept for the life of swap
and for a period of no less
than five years, following
the termination, transfer, or
The Dodd-Frank Wall Street Reform and Consumer Protection Act, which
was signed into law on July 21, 2010, provides for a comprehensive
set of regulatory changes and increased reporting and compliance
requirements impacting financial services firms including investment
banks, securities trading firms, insurance companies, and consumer
A key provision of the Act (Title VII) demands increased discipline in
the reporting and recordkeeping of over-the-counter (OTC) swap and
derivative-related transactions. The major premise of this provision is
to provide “readily accessible” records of all information (both oral and
written) leading to the execution of swap trades and within a 72-hour
What If You Could...
- Assess your current ability to comply with the regulation?
- Identify gaps in your trade repository and archive?
- Mitigate the risks of potential fines and reputational damage by
- implementing a compliant program?
The CFTC ruling applies to any and all forms of records, whether the trade
was requested via email, instant message, over the phone, fax, or video chat.
In order to comply with the ruling you must provide “readily accessible”
records of all information (both oral and written) leading to the execution
of swap trades and within a 72-hour response timeframe.
Iron Mountain offers advisory consulting and systems integration services that deliver best-in-class information management solutions meeting the specific needs of our financial services customers.Specializing in enterprise information management we help clients leverage information assets for better business results. Through deep domain knowledge of industry practices,tailored solutions, and specialized technology, clients achieve operational efficiency,business scalability, and regulatory compliance.
An Integrated Approach to Dodd-Frank
Iron Mountain evaluates the various aspects of the organization’s processes
and technologies and tailors solutions to serve the specific needs of swap
dealers and other companies in dealing with the reporting requirements of
the Dodd-Frank Act.
Compliance Response System
We conduct a thorough assessment of current data storage and retrieval
capabilities and available technology to optimize response times and ensure
compliance with all federal reporting and record keeping requirements. By
establishing and maintaining best practices in record keeping and reporting,
companies can ensure Dodd Frank compliance and improve their position in
the regulatory environment.
Trade Detail Reporting Repository
We help firms ensure that the appropriate reporting required from dealers
and swaps and derivatives counterparties is accessible in real-time and near-real-
time — and, in the case of global organizations, according to country
specific requirements — to achieve compliance.
While voice communications are essential to the day-to-day
interactions of financial services firms, they also present
the most significant challenge in Dodd-Frank compliance.
We help organizations establish a best practices approach
to optimizing their environment and a plan to appropriately
Email Archive Search
Improvement to existing email archive solutions may be
necessary to allow companies to manage the search and
retrieval of relevant messages under Title VII of Dodd-
Frank. Record storage and retrieval must be streamlined
and optimized to allow for faster reconciliation and
compression on the part of investment firms. We evaluate
available technologies to determine the right solution for
Managing Increased Requirements.
What You Gain
Our solutions’ proven assessment framework appraises our
current processes and record retrieval capabilities for trade
reconstruction reporting and suggests enhancements
to reduce response times and ensure compliance with
all federal reporting requirements. Some areas that are
- Processes for responding to Dodd Frank related
- Current capacity for responding to requests within three
- Record retrieval technology used to report swaps and
derivative related transactions
- Identifies increments of investment options to meet or
aggressively meet reporting requirements
Our six-week assessment benchmarks the current state
and identifies strengths, weaknesses, and opportunities
to achieve reporting goals through a set of cost benefit
options. Iron Mountain then produces a phased
implementation roadmap that will enable the organization
to achieve the future state and improve their compliance
Iron Mountain’s Assessment
Our team will leverage its proven roadmap
assessment methodology in evaluating the
organization’s regulatory response process
inclusive of supporting technologies.