CFTC Rewrite:
how should firms respond?

Regulations are changing fast. No amount of point solutions can keep up or meet the exacting new standards. But technology has evolved to offer agility, transparency and governance.

How can firms embrace this? Find the latest insights from technology and industry experts on changing your approach to regulatory reporting.


  • What is the CFTC Rewrite?

    The Commodity Futures Trading Commission (CFTC) Rewrite is an update to over-the-counter (OTC) derivatives reporting rules first introduced under the Dodd-Frank Act in 2010. It aims to improve reporting data quality and create more transparent markets and applies to Swap Data Repositories (SDRs) and reporting counterparties.

  • When does the CFTC Rewrite go live?

    Phase I of the CFTC Rewrite goes into effect on 5 December, 2022. Phase II is expected to go live in late 2023.

  • What are the main changes coming in the CFTC Rewrite?

    The CFTC is adopting a much more prescriptive approach. Phase I of the CFTC Rewrite reduces the number of reportable fields to 128, introduces critical data elements (CDE) such as the Unique Transaction Identifier (UTI), shortens the deadline for swap reporting to T+1 and obliges firms to flag any reporting errors within seven days.

    Phase II will introduce the Unique Product Identifier (UPI) field and move to ISO20022 XML messaging standards.

  • What instruments are affected by the CFTC Rewrite?

    The CFTC Rewrite covers trades of Non-Security-Based-Swaps (Swaps) regulated by the CFTC:

    • Interest Rate Swaps
    • FX swaps and forwards (excluded from central clearing and trade execution requirements)
    • Credit default swaps (CDS) or broad based indices; baskets of single name CDSs
    • Agricultural and Commodity Swaps
    • Some Total Return Swaps
    • All options based on rates (interest rates, currency rates)
    • All options based on commodities, with exceptions for some physically settled contracts
    • Metal and energy swaps, with some exceptions
    • Any guarantee of a swap
  • Is CFTC single-sided reporting?

    The US is a single-sided reporting regime. This means that one counterparty reports for both sides. However, it can be complicated to decide which counterparty is responsible for reporting (see below).

  • Who has to report to the CFTC?

    Firms trading over-the-counter (OTC) derivatives in the US, or US residents buying foreign OTC derivatives, must report the details of the trade to a Swap Data Repository (SDR). However, Dodd-Frank requires only single-sided reporting. Who should report the transaction is based on several criteria, including the type of asset being traded and the types of firms involved in the trade. Different criteria apply depending upon if one or both counterparties are US citizens. Entity types are ranked hierarchically with regards to reporting obligations, with Swap Dealers at the top.

    Find the full CFTC reporting guidelines here.

  • What is a Swap Data Repository?

    Swap Data Repositories (SDRs) were created under the Dodd-Frank Act. All cleared and uncleared swap transactions must be reported to registered SDRs. Under Section 21 of the Commodity Exchange Act, SDRs must register with the Commodity Futures Trading Commission (CFTC) and have core duties and responsibilities to fulfil. These include real-time reporting of swap transactions and pricing data.

Industry experts weigh in on the CFTC Rewrite

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These are personal views and do not necessarily represent the views of the individual’s firm.

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