Midwestern regional bank with $2.5 billion in assets.

Active in C&I and CRE lending.

Had existing portfolio of interest rate hedging transaction booked prior to Dodd-Frank implementation.


Navigating Dodd-Frank: Regional Bank’s Derivative Program Success


  • Had to consider their ability to continue offering interest rate derivatives as a product solution in a post-Dodd-Frank environment.

  • With no in-house infrastructure and resources to address the complex regulatory requirements, the bank was forced to a) evaluate its ability to continue servicing its existing derivatives portfolio and b) question whether it could continue to offer new derivative hedging solutions to its commercial clients.

  • Desire to remain competitive in winning commercial loans vs. larger banks with greater legal, compliance, and capital markets resources to support a more regulated client hedging program.

  • Desire to continue to diversify revenue and create non-interest income opportunities.


  • The Bank signed on with Derivative Path, Inc. in 2013 and utilized the team as their fully outsourced derivative program solution.

  • DPI onboarded and reconciled over 150 existing derivative positions in less than 2 weeks onto the DerivativeEDGE trading platform.

  • Ensured all existing positions were properly hedged, documented and being reported accurately to the Swap Data Repository.

  • Negotiated new ISDAs and expanded access to trading liquidity with newly established Swap Dealer relationships.

  • On a daily basis, produce white-labelled payment notices and reconcile them to dealer notices ready to deliver to clients, eliminating hours of manual copy paste processes.

  • Provide monthly client mark to market statements.

  • Reviewed bank credit and risk management policies.

  • Provide ongoing assistance with full trade lifecycle processing.

  • After hiring DPI, have had the business pass internal audits and other reviews.

  • Continue to offer hedging solutions to eligible commercial clients and compete very effectively with large and small banks alike.