SEC has published reporting obligations for SBS without a finalized compliance schedule. Reporting rules for cleared and platform-executed SBS and certain cross-border transactions have not yet been finalized.

On February 11, 2015, the Securities and Exchange Commission (the SEC) issued a final rule regarding regulatory reporting and public dissemination of security-based swaps (i.e., credit default swaps and other equity derivatives) (Regulation SBSR). On the same date, the SEC proposed a phased-in compliance schedule for Regulation SBSR along with additional rules and guidance in respect of Regulation SBSR (the Proposed Amendments Release). Under Regulation SBSR, security-based swaps entered into or guaranteed by security-based swap dealers, major security-based swap participants or US persons, as well as security-based swaps accepted for clearing by US clearing agencies, must be reported to a registered security-based swap data repository. Subject to certain exclusions and exceptions, the repository must in turn publicly disseminate such information. While the rule becomes effective on May 18, 2015, the phased-in compliance schedule has not yet been finalized. As a result, only certain aspects of Regulation SBSR will become effective on the effective date, and the prescribed regulatory reporting and public dissemination requirements will be effective pending a proposed phased-in compliance period, as discussed further herein. The SEC has requested comment on the Proposed Amendments Release by May 4, 2015.