Designing booking entity structures under the Dodd-Frank act

Designing booking entity structures

The Dodd-Frank Act has significantly changed the regulatory model for all financial services companies in the US. The act has, in particular, brought the ‘over-the-counter’ (OTC) derivatives market under federal supervision. One of the provisions of the acts - the Swaps Push-out provision - will have significant implications on the swaps entities. However, the new rule contains many ambiguities with respect to capital, margin, and segregation requirements.

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The Swaps Push-out provision will trigger substantial changes in banks’ oversight and eligibility under Push-out rules. To combat this, institutions should start developing a strategic booking entity corporate structure based on existing product mix, current customer base, and regulatory supervision.

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