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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 U.S. 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. 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

Read more for how banks will move forward as well as key decisions banks may face.

As used in this document, “Deloitte” means Deloitte & Touche LLP, a subsidiary of Deloitte LLP. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

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