SEC Extends Swap Dealer Rules: No Drama, Just Continuity
Published Date: 5/14/2025
Notice
Summary
The SEC wants to keep Rule 18a-3 going, which helps nonbank security-based swap dealers keep an eye on risky trades and follow safety rules. About 13 dealers spend around 60 hours a year making sure everything’s in check, so the paperwork and time stay about the same. No big changes or costs, just a smooth extension to keep the financial playground safe and sound.
Analyzed Economic Effects
3 provisions identified: 1 benefits, 2 costs, 0 mixed.
Account-Level Risk Monitoring Duty
If you are a nonbank security-based swap dealer (SBSD), Rule 18a-3(e) requires you to monitor the risk of each account that holds non-cleared security-based swaps and to establish, maintain, and document procedures and guidelines as part of your risk management control system under Exchange Act Rule 15c3-4. The SEC estimates there are 13 nonbank SBSDs and that each spends about 60 hours per year on these reviews, for an industry total of about 780 hours annually.
Model Approval and Maintenance Burden
A nonbank SBSD that seeks approval to use an internal model to calculate initial margin must go through an application process consistent with Exchange Act Rule 15c3-1e and Rule 18a-1(d). The SEC estimates one nonbank SBSD uses such a model and will spend about 250 hours per year reviewing, updating, and backtesting its initial margin model.
No Estimated Ongoing Monetary Cost
The Commission estimates there is no annual monetary cost burden associated with Rule 18a-3 because previously estimated start-up costs have already been incurred. The SEC treats the current action as an extension of the existing collection of information.
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