On September 30, 2015, the US CFTC issued its first action enforcing new requirements issued pursuant to Dodd-Frank that provide for real-time public reporting of swap transactions and the reporting of swap data to swap data repositories, against Deutsche Bank. The Order finds that Deutsche Bank, a provisionally registered Swap Dealer, failed to properly report its swaps transactions and did not have a satisfactory supervisory system governing its swaps reporting requirements. Deutsche Bank is required to pay a $2.5 million civil monetary penalty in addition to complying with certain steps to improve its internal controls related to the accuracy of its swaps reporting.

The CFTC press release is available at: http://www.cftc.gov/PressRoom/PressReleases/pr7255-15.

The CFTC Order is available at: http://www.cftc.gov/idc/groups/public/@lrenforcementactions/documents/legalpleading/enfdeutscheorder093015.pdf