September 15, 2015
I support issuing this proposal to amend the definition of “material terms” for purposes of portfolio reconciliation performed by swap dealers and major swap participants.
The proposed amendment would replace an existing “no-action” letter issued during the implementation of the Dodd-Frank Act. This gives greater certainty to affected registrants and furthers the Commission’s ongoing process of simplifying, fine-tuning, and harmonizing our rules.
The proposal not only seeks comment on the technical aspects of reconciling specific data fields excluded under the staff no-action letter, but also seeks answers to important questions regarding the experience of swap dealers and major swap participants in complying with the portfolio reconciliation requirement more generally. Further, it seeks comment on the relationship of portfolio reconciliation to the integrity of data reported to swap data repositories.
The feedback of knowledgeable market participants on this proposal will allow the Commission to further its goal of continuously improving our recordkeeping, reporting, and data quality rules and practices. I encourage all market participants to join in this effort by examining the proposal and providing detailed comments. I look forward to reviewing them.
Last Updated: September 15, 2015