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Reporting
   
  Under the US Dodd-Frank Act, there is a requirement for all trades valued t+3 and greater to be reported to a “Swaps Data Repository”.
 
Under this requirement one party to the trade must bear the responsibility to ensure that the trade is reported. The CFTC in their rule making has created a hierarchy whereby Swaps Dealers always report when trading with Major Swap Participants and End Users, Major Swap Participants always report when trading with End Users.
 
Under this requirement one party to the trade must bear the responsibility to ensure that the trade is reported.