SEC Instructs SBS Entities on Document Submissions under Financial Responsibility Rules

SEC Division of Trading and Markets ("Division") staff instructed security-based swap ("SBS") entities on documentation submissions under (i) SEC capital margin and segregation rules (SEA Rules 18a-1 to 18a-10) and (ii) SBS valuation dispute notices pursuant to SEA Rule 15Fi-3 ("Security-Based Swap Portfolio Reconciliation").

As to dispute notices, no specific fields are required, but the Division encouraged SBS entities to include (i) identifying information about both counterparties (including each of their Legal Entity Identifiers), (ii) the date of the dispute, (iii) the type of dispute, (iv) the receiver and the payer, and (v) the disputed amount in U.S. Dollars.