Dodd-Frank – Title VII – Are you ready?


Registered participants must keep records of all trade activities and provide reports to the regulators. The recordkeeping rules under Title VII are mandatory for Swap Dealers (SD) and Major Swap Participants (MSP).

Transactional records – These are records that are associated with trades, or daily trading records. All of the records that make up a trade are included:

  • Pre-trade execution – All oral (fixed, cellular phone and voice mail) and written (email, chat, SMS, fax) communication that led to trade execution. For example, Bloomberg chat identifying several potential trades followed up with a phone call confirming particular trade to be executed.
  • Trade execution – All information entered into a trade order system necessary for trade execution.
  • Post-trade execution – All post-trade specific information, including confirmation, termination, novation, amendment, assignment, netting, compression, reconciliation, valuation, margining and collateralization”