SEC Provides Relief to Security-Based Swap Dealers from Business Conduct Rules: Relief From Certain Documentation Requirements Under the SEC’s Business Conduct Rules Would Apply for Five Years After the Registration Requirement Takes Effect

Sullivan & Cromwell LLP - November 5, 2018
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On October 31, 2018, the U.S. Securities and Exchange Commission issued a statement setting forth its position that failure to comply with certain documentation requirements of the SEC’s business conduct rules applicable to registered security-based swap dealers and major security-based swap participants will not provide a basis for a SEC enforcement action.  The statement seeks to harmonize the SEC’s business conduct rules with the swap dealer business conduct rules that have been adopted by the U.S. Commodity Futures Trading Commission.  The relief would expire five years following the compliance date of the registration requirements for security-based swap dealers and major security-based swap participants.