On December 19, 2018, the Securities and Exchange Commission proposed rules requiring the application of risk mitigation techniques to uncleared portfolios of security-based swaps by registered security-based swap dealers and registered major security-based swap participants (“SBS Entities”). The proposed rules would require SBS Entities to periodically reconcile outstanding security-based swaps with applicable counterparties, engage in portfolio compression exercises and execute written security-based swap trading relationship documentation with each of its counterparties prior to, or contemporaneously with, executing a security-based swap transaction.