On Friday, March 30th, the Federal Reserve Board, the OCC and the FDIC clarified that the effective date of the Swap Push Out Provision – Section 716 of the Dodd-Frank Act – is July 16, 2013.
The press release and official guidance are available here.
And, for the record, we first asserted this in July 2010 – although, admittedly, we asserted July 15, 2013, instead of July 16, 2013 (which I still say was not bad given everything that was going on back in the glorious summer of 2010. Don’t believe me? You can look at our July 2010 Title VII Teleseminar summary available here – and, before somebody says it, NO – we did not plant the answer that we wanted in that summary! If we were going to do that, we would have change July 15 to July 16. Unless, of course, we wanted to give you the appearance of having nailed it…Don’t even think it – I am joking!
Let’s be honest: the real point of this posting is not our July 2010 Teleseminar summary…it is the March 30, 2012 position of the bank regualtors…and, admittedly, they could have gone either way 2012 or 2013, depending upon their view of whether "Act" meant DFA or Title VII.
Good day. Good clarification. TSR