Dodd-Frank Compliance

Managing Director

SFG assists clients in understanding and complying with the web of Dodd-Frank and CFTC regulations that now govern the over-the-counter derivatives market. Members of our firm spent many hours with political staff members during the drafting of the Dodd-Frank Act and SFG has made various comments to the CFTC as it has set forth new rules for the market. We serve as a Qualified Independent Representative (“QIR”) for our non-ERISA “Special Entity” governmental and municipal clients, and as an Independent Registered Municipal Advisor (“IRMA) for our “obligated person” clients that engage in tax- exempt securities and derivative products.

We’d be happy to assist with the following:

  • QIR/IRMA representation
  • ISDA Dodd-Frank Protocols
  • Dealer-specific Dodd-Frank “bilateral” agreements
  • Global Markets Entity Identifiers (GMEIs) or Legal Entity Identifiers (LEIs)
  • Verification of Eligible Contract Participant (ECP) status
  • Exemption from variation margin requirements
  • Qualified Financial Contract (QFC) Stay Rules
  • Drafting and/or review of hedging and debt policies


SFG is registered with both the Securities and Exchange Commission (Registration No. 866‐00314‐00) and Municipal Securities Rulemaking Board (Registration No. K0219) as a Municipal Advisor. All of SFG’s employees have passed the Municipal Advisor Representative Qualification Examination (Series 50 exam) and SFG is fully compliant with the conduct standards for municipal advisors as set forth by MSRB Rule G-42. We are also registered as a Commodity Trading Advisor (“CTA”) with the National Futures Association.