EDMC-FIBO/FBC 1.1 RTF Avatar
  1. OMG Issue

FIBOFBC11 — Need the generic concept of a legal agent from a financial services perspective

  • Key: FIBOFBC11-14
  • Status: open  
  • Source: Thematix Partners LLC ( Elisa Kendall)
  • Summary:

    This concept should be a child of PartyInRole, and a parent of two additional new classes, ThirdPartyAgent and LicensedAgent, per the CFTC requirement, with a definition similar to "An agent in the financial sense is any person who has been legally empowered to act on behalf of another person." See the 17 CFR Part 45 and
    "The term “registered entity” includes SEFs and DCMs. See CEA sections 1a(40)(A), (C) and (D), 7 U.S.C. 1a(40) (A), (C) and (D). The Commission stated in the RTR Adopting Release that SEFS and DCMs may enter into a contractual relationship with a third party service provider to transmit swap transaction and pricing data to an SDR; however, the SF or DCM will remain responsible for such reporting requirement pursuant to part 43. RTR Adopting Release at 1201." which we are calling ThirdPartyAgent in SEC (issuance).

    Two concepts are required to cover the general notion of a registered agent because of the separation between organizations and individuals in FIBO. Thus, a ThirdPartyAgent is a service provider (organization) and licensee that has the authority to act on behalf of another individual or organization, such as a law firm, accountancy, or investment bank. LicensedAgent is a responsible party (individual) and licensee that has the autority to act on behalf of another individual organization, such as an insurance agent, financial advisor, certain attorneys, and brokers.

    http://www.cftc.gov/idc/groups/public/@newsroom/documents/file/specificationsswapdata122215.pdf

  • Reported: EDMC-FIBO/FBC 1.0 — Wed, 3 May 2017 00:32 GMT
  • Updated: Sun, 7 May 2017 00:19 GMT
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