October 17, 2014
Best practice to remedy Swap Dealer (SD) trade bookings and reporting by the relevant Reporting Counterparty under the CFTC’s P43 and P45 rules for edge cases, where a client executes a new trade either on or off-facility, and then advises the SD that the trade is actually an unwind or novation of a pre-existing bilateral trade and requests that the SD remedy in accordance with their intention.
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