Ensuring Dodd-Frank Regulatory Compliance for Counterparty Data

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Summary

To increase transparency in the financial system and mitigate risks on any future market collapse, Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) required systemic changes in reference data requirements on all counterparty data. Our client, a European-based multinational financial investment firm, requested Sagence’s help to manage a phased implementation of these standards in their client reference data systems that required re-classification of pre-existing accounts and a new counterparty onboarding process.

Challenge

The Dodd Frank Wall Street Reform established business conduct standards for swap dealers and swap participants with counterparties.  In order to comply with the rules adopted by the CFTC, swap dealers must obtain “know your counterparty” information and verify that these counterparties qualify as “eligible contract participants.” This information must be stored by the Bank and reported to regulators.

Solution

The Bank used SharePoint for client onboarding to manage counterparty information provided via DF ISDA protocols or bi-laterally directly with the firm.  Sagence worked with the client to implement a “phased” approach to managing the data mandated by this regulation:

  1. The Sagence team updated the internal client reference data systems to incorporate a counterparty’s DF ISDA Protocol elections into the onboarding workflow and to store/distribute these elections.
  2. We connected the internal system to the external data source for a global reference data repository run by a third party to automate the data population of the Bank’s derivative counterparties’ ISDA reference data.

Results

The client was able to meet all regulatory compliance deadlines, which systematically improved the quality of client reference data and increased efficiency of the client onboarding team via integrating with the external data provider. Additionally, data distribution allowed for pre-trade and post-trade data to be sent to impacted business units through the bank.