As the rules pertaining to swap dealer registration under Title VII of the Dodd-Frank Wall Street Reform Act (“Dodd-Frank”) are now finalized, swap dealers (SDs) and major swap participants (MSPs) are now required to register with the SEC and/or the CFTC to continue trading on behalf of “US persons” (i.e. US-based clients).  Across Wall Street, Monticello Consulting is seeing its investment banking clients undertake time-critical projects in order to make significant changes to both their business processes and technology platforms in order to comply with Dodd-Frank rules.