Global Investment Bank
Program Manager for Dodd-Frank Title VII
- The client was required to meet regulatory obligations to ensure all commodity derivatives trading, on either a principal or agency basis, by the institution facilitating the trade must conform to rules set by the Commodity Futures Trading Commission (CFTC) as per Title VII of Dodd-Frank Act.
- The challenge for the client was to start the planning process without clearly defined rules being published by the regulators. Numerous calculated assumptions and risks were taken to start planning early on, but avoid unnecessary development work that could be impacted by variations in the final rules.
- Key components of the engagement were to ensure that all impacted lines of businesses globally were included, define an approach that ensured compliance where regulatory guidance was not complete, locate all existing known issues and develop and/or purchase system infrastructure as needed.
- Established a project management office, working groups, and steering committee project governance model to manage project oversight from the various work streams, fostered decision making for all related activities as well as to ensure synergies with other Dodd-Frank regulatory initiatives.
- Workstreams include: Swap Dealer Registration, Migrating Swap Positions to allow for access to the Fed Discount Window, Processing of Uncleared Transactions, Record Retention (pre-execution, execution and post-execution), Legal Documentation, Transaction Reporting (real time and Primary Economic Terms), Large Trader Reporting, Position Limits Monitoring, Risk Management Framework (Swap Dealer and FCM), Client Classification, Business Conduct Rules, Swap Execution Facilities, Centralized Clearing.
- Worked with internal Legal/Compliance and external counsel to interpret the regulations and determine what areas in the firm will be impacted.
- Conducted a current state analysis to assess existing systems and processes to determine if they can be enhanced to meet the future state.
- Conducted a vendor analysis review to identify technologies available that can meet and/or assist with the requirements.
- Managed a build vs. buy analysis with front office, technology, operations and compliance groups.
- Managed the development, testing and deployment of all solutions.
- Client was prepared to meet compliance for defined deliverables of the regulation based on the proposed rule.
- Client was ahead of the curve in planning and deployment of processes and technologies to support pending undefined rules.