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Vedder Thinking | Articles SEC Approves the First Security-Based Swap Data Repository and Sets the Compliance Date for Regulation SBSR


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On May 7, 2021, the SEC announced its approval of DTCC Data Repository (U.S.), LLC (DDR) as the first security-based swap data repository (SDR)—meaning that the security-based swap market now has a centralized database to facilitate reporting and regulatory surveillance of transactions in security-based swaps (i.e., credit default swaps and other equity derivatives).  DDR will operate as a registered SDR for security-based swap transactions in the equity, credit and interest rate derivatives asset classes.

The announcement also set November 8, 2021 as the first compliance date for Regulation SBSR, which regulates reporting and public dissemination of security-based swap transactions.  Under Regulation SBSR, security-based swaps entered into or guaranteed by security-based swap dealers, major security-based swap participants or U.S. persons, as well as security-based swaps accepted for clearing by U.S. clearing agencies, must be reported to a registered SDR.  Subject to certain exclusions and exceptions, the SDR must, in turn, publicly disseminate such information.  The regulation stipulates that the first SDR can accept transaction reports in a particular asset class six months after the registration date.  Regulation SBSR was mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act to provide transparency to the security-based swaps market.   

The SEC’s order approving DDR’s application for registration as a SDR is available here.



John S. Marten


Nathaniel Segal


Jacob C. Tiedt