Swap Confirmations and Acknowledgments

Overview

Swap dealers and major swap participants are required to adhere to certain standards for the timely and accurate confirmation of swap transactions and for the reconciliation and compression of swap portfolios. For swap transactions with a person who is a swap dealer or major swap participant ("MSP"), the confirmation must be executed as soon as technologically practicable, but not later than the time periods set forth in CFTC Rule 23.501.

These obligations vary depending upon whether the particular swap transaction or portfolio is between a swap dealer and an MSP or involves other types of counterparties. They do not apply to swap transactions executed on an SEF or DCM, provided that the rules of the SEF or DCM establish that confirmation of all terms of the transaction shall take place at the same time as execution. They also do not apply to transactions submitted for clearing by a DCO, provided that (i) the transaction is submitted for clearing as soon as technologically practicable, and (ii) confirmation of all terms of the transaction takes place at the same time that the transaction is accepted for clearing.

Steven.Lofchie@cwt.com's picture
Contributor Organization 
Contributor Title 
Partner
nihal.patel@cwt.com's picture
Contributor Organization 
Contributor Title 
Special Counsel

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Swap and SBS Confirmations