The Securities and Exchange Commission adopted final rules establishing recordkeeping and reporting requirements for security-based swap dealers, as was required under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The requirements are similar to those to which broker-dealers are currently subject. The new rules also require non-broker-dealer SBSDs to make and keep current financial and accounting records related to their security-based swaps activity and establish notification requirements when their capital declines below required amounts. Non-US-based SBSDs may potentially take advantage of substituted compliance with home jurisdiction requirements to satisfy their SEC recordkeeping and reporting requirements, while SBSDs that are not otherwise SEC-registered but are registered with the Commodity Futures Trading Commission as swap dealers may apply solely with CFTC requirements. The SEC’s new rules are effective 60 days after publication in the Federal Register, while the compliance date is not until 18 months after the effective date of final rules regarding the cross-border application of certain security-based swap obligations.