SEC Eases Swap Trading Limits for Big Financial Players
Published Date: 1/14/2026
Notice
Summary
The SEC is giving some companies a temporary break from certain rules about how much security-based swap trading they can do without being labeled dealers. This relief mainly helps firms dealing with credit default swaps and other security-based swaps by letting them count bigger trading amounts for a little while. It’s a short-term change to ease the transition, with no immediate cost impact but important for those tracking their trading limits.
Analyzed Economic Effects
2 provisions identified: 2 benefits, 0 costs, 0 mixed.
Higher de minimis thresholds through May 8, 2028
If you are not currently registered as a security-based swap dealer (SBSD), you will not be treated as an SBSD through May 8, 2028 even if your prior 12 months' security-based swap dealing exceeds the $3 billion (CDS) or $150 million (non-CDS) thresholds, provided your aggregate gross notional dealing in the prior 12 months is no more than $8 billion for CDSs and $400 million for non-CDSs.
Registered dealers can withdraw if within phase-in range
If you are a currently registered SBSD that has been registered at least 12 months, you may apply to withdraw your SBSD registration and continue dealing in reliance on the phase-in levels until May 8, 2028 if your prior 12 months' aggregate gross notional is over $3 billion but no more than $8 billion for CDSs, or over $150 million but no more than $400 million for non-CDSs.
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Key Dates
Department and Agencies
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