ARTICLE
25 January 2022

FINRA Sets Compliance Dates For Security-Based Swap Rules

CW
Cadwalader, Wickersham & Taft LLP

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FINRA set the compliance dates for rule amendments relating to security-based swaps.
United States Finance and Banking

FINRA set compliance dates for rule amendments relating to security-based swaps ("SBS").

As previously covered, the SEC approved FINRA proposals to amend or adopt the FINRA Rules: 0180 ("Application of Rules to Security-Based Swaps"); 4120 ("Regulatory Notification and Business Curtailment"); 4210 ("Margin Requirements"); 4220 ("Daily Record of Required Margin"); 4240 ("Margin Requirements for Credit Default Swaps"); and 9610 ("Application") to account for its members' SBS activities.

As established in Regulatory Notice 22-03, the changes will become effective as follows:

  • New Rule 0180 and conforming changes to Rule 9610 become effective on February 6, 2022.
  • Amendments to financial responsibility and operational rules, including Rule 4120, to conform to SEC SBS requirements, also become effective on February 6, 2022.
  • New SBS-specific margin requirements under Rule 4240 and changes to Rules 4210 and 4220 become effective on April 6, 2022.

Primary Sources

  1. Regulatory Notice 22-03: FINRA Adopts Amendments to Clarify the Application of FINRA Rules to Security-Based Swaps

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