More updates on swaps and proposed changes introduced shortly after a prior adoption…….Small business need-to-know and news-to-watch.
Excerpt……….When adopting the Real-Time Reporting Rules, the Commission determined not to adopt the methodology for determining minimum block sizes it proposed in December of 2010. The Commission agreed with commenters that additional analysis of swap data was necessary in order to determine properly the appropriate minimum block sizes. On February 23, 2012, the Commission voted 3-2, with Commissioners Sommers and O’Malia dissenting, to promulgate the Proposed Rules. The Proposed Rules contain provisions in furtherance of the Real-Time Reporting Rules, including provisions that “(1) specify the criteria for determining swap categories and methodologies for determining the appropriate minimum block sizes for large notional off-facility swaps and block trades and (2) provide increased protections to the identities of swap counterparties to large swap transactions and certain other commodity swaps, which were not fully addressed in” the Real-Time Reporting Rules. The Proposing Release posed 108 questions, many of these questions with multiple parts, to prospective commenters, and included possible alternatives to the Proposed Rules and the methodologies contained therein.