Hi Debi, I'll introduce myself since I don't post to the list too often, my
name is Vicki Lemieux and I'm a professor at the University of British
Columbia and Director of the Centre for the Investigation of Financial
Electronic Records.  

In response to your question about recordkeeping rules put forward under
DFA, the Commodities and Futures Trading Commission on 18 May issued its
Final Rule on Swap Data Recordkeeping and Reporting Requirements for
Pre-Dodd-Frank and Transition Swaps.  Here's a link to the text in the
federal register:
http://www.cftc.gov/ucm/groups/public/@lrfederalregister/documents/file/2012
-12531a.pdf.

Among the new requirements, which go much broader than retention into such
matters as reporting and registration of derivatives, the CFTC sets out
several requirements for retention of various types of swaps records in
chapter 46.2 of the rules.  

I hope this info is helpful.

Vicki.


-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of Tadd, Debi
Sent: August-30-12 1:49 PM
To: [log in to unmask]
Subject: Reintroduction & Question

Hi all!

It has been a while since I've posted to the list, so I'll reintroduce
myself. My name is Debi and I work as a Records Analyst for a Financial
Institution.   My group has been approached by a couple of business units
that are being affected by the Dodd Frank Act.  They are concerned about
ensuring they are abiding by the new rules put forth by the Act.

My question is for other financial institutions.  In my research on how this
affects RIM, I have found reference to retention of records, but it's
basically stating we must have a retention schedule and it must be followed.
(We do).  I am drawing the conclusion that this Act has more to do with the
processes and procedures the business unit must follow in regard to
investments and mortgage backed securities.  Does anyone else have
additional information on how this affects RIM?  Do you have any suggestions
to the business units based on your company's experience with this?

You are welcome to email me directly if that is more convenient.  Thank you
for your help and I look forward to hearing your input.

BBVA Compass
Debi Tadd
Records and Information Management Analyst Tel. 512-453-4272 - Fax
512-453-0899 - Mobile 512-284-2035 -
[log in to unmask]<mailto:[log in to unmask]>
Shoal Creek - 7951 Shoal Creek, Austin, TX  78757 TX-AU-SH-PMG

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