Too Big to Fail, Not Anymore - How swap dealers can comply with Dodd-Frank regulations by Tara Holt

The Dodd-Frank Wall Street Reform Act (DFA) drafted in reaction to the 2008 financial crisis and signed into law in 2010 reaches its third anniversary in July, and financial institutions are still working to gain compliance with the new regulations.

The DFA is designed to enforce more transparency and accountability within financial institutions with the goal of reducing the risk of another widespread financial meltdown. It ushers in rigorous and lasting recordkeeping compliance obligations for United States financial institutions, such as swap dealers, fund clearing houses, and other derivatives-related entities, that must store records using a records management program approved by the Commodity Futures Trading Commission (CFTC) and that those records must be made immediately available and be readily accessible to the CFTC or other government agency upon request.

Iron Mountain is well-suited to offer regulated financial institutions such as swap dealers a suite of services to meet these recordkeeping requirements, including Records Management, Data Backup and Recovery, and Designated Third Party Compliance Services.

Iron Mountain D3P Services, in particular, help swap dealers comply with DFA Section 17 CFR 1.31. Our services also offer similar protections for broker dealers subject to Security Exchange Commission (SEC) Rule 17a-4 regulations.

We provide our services online or onsite depending on your requirements. With both options, you receive:

Letter of Intent to regulators that you contracted a Designated Third Party Provider, referred to as the Technical Consultant within Dodd-Frank

System Configuration Plan (SCP) explaining access to records

Two D3P Status Reviews each year to validate D3P accountability

Annual test and test report to show compliance

Letter of Undertaking for filing with CFTC, SEC, and Self-Regulating Organizations

Up to 2 days for an SEC or CFTC auditor at D3P facility

Traditional escrow services to support your D3P services

Iron Mountain has many years of experience helping companies comply with CFTC and SEC regulations and is uniquely suited to act as your trusted neutral third party technical consultant. We can assist you when facing an audit and when proactively ensuring compliance when facing new regulations.

LINK:	http://blogs.ironmountain.com/2013/service-lines/technology-escrow/too...
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