Swap Portfolio Reconciliation

Overview

The CFTC's "Portfolio Reconciliation" requirement is intended to force parties to swaps to confirm their understanding of the open transactions between them and as to the approximate valuation of those positions. If the amount of the disagreement between two counterparties is of a sufficient size and is not resolved within a prescribed time, then the parties must notify the regulators.

The Portfolio Reconciliation requirement, like the Swap Portfolio Compression requirement, is part of the CFTC's "Trading Documentation" rules, although the focus of these rules is not documentation, but rather risk management or risk mitigation.

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Special Counsel

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Portfolio Reconciliation