Dodd-Frank Act Push-out | Deloitte US | Center for Regulatory Strategies


Stronger: OCC's heightened expectations

The OCC formalized its heightened expectations for risk management through its proposed minimum standards, creating greater regulatory involvement. 


Dodd-Frank Act push-out

Planning the right strategy

Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) outlines a framework for US regulatory agencies to regulate the over-the-counter (OTC) swaps market and, at the same time, creates a higher degree of clarity and transparency amongst market participants.

In compliance with “push-out” in 2015

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Learn more about extension process in Dodd-Frank Act

Under the Dodd-Frank Act, banks had until July 16, 2013 to “push out” certain swaps into an affiliate unless they were granted a two-year extension. Applying for that extension required filing an explanation of the bank’s plans relative to push-out of eligible swaps as defined in Dodd-Frank. As a result of the extension process, many banks are now focused on the decisions that they need to make and determining the best course of action to be in compliance with “push-out” in 2015. In this paper we highlight the following:

  • Market impact
  • Business case decision
  • Registration and potential capital implications
  • Some key considerations


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David Wright

Managing Director | Banking and Securities