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. 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).