Comment Text:
75 FR 81519
A. Swap Confirmation
2. Confirmation Rule
I suggest a swap is confirmed when all parties accept the terms and no change to the terms would be legally binding until all parties agree to said changes.
Compression Rule
The focus is Dodd-Franks is transparency. Any changes made to a portfolio should be documented and reversed calculated, the compressed transaction can be uncompressed. All parties economically involved with swap must be notified and provided documentation to insure both entities accounting records balance.
IIII Related Matters
A. RFA
I worry declaring entities to small for reporting. Offers an opportunity to make a shell company to move liabilities off an entities balance. I am reminded of Enron.
The records of swaps should contain data to reconstruct all transactions involving said swaps. For reporting requirements a dealer would only need to present the final agreement of a swap.
