CFTC (Dodd-Frank) Reporting

The Swap Data reporting rules are the US government's response to the 2007/8 financial crisis and the G20 Pittsburgh agreement that banks and financial firms must report all OTC derivative trading activity so that regulators could monitor systemic risk. The rules are part of the Dodd-Frank Act and overseen by the CFTC and the SEC.

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What is CFTC Reporting?

Firms trading OTC derivatives in the US must report details to a registered Swap Data Repository (SDR). The reporting obligations include:

  • Part 43 real-time reporting to provide transparency on pricing to the market
  • Part 45 transaction reporting to allow regulators to monitor for systemic risk.

The Commodities and Futures Commission (CFTC) oversees the reporting which includes all other OTC derivatives for Credit*, Equity*, FX, Interest Rates and Commodities asset classes.

CFTC reporting commenced in 2013 with DTCC, CME and ICE operating SDRs. The CFTC has also implemented a substantial revision of the reporting rules, known as the CFTC ReWrite, and reporting under the new rules commenced in December 2022.

UPI (Unique Product Identifier) was adopted in January 2024 for Credit, Equity, FX and Interest Rates asset classes. UPI adoption for Commodities is currently unscheduled but anticipated at some point in 2025.

*Certain Credit and Equity transactions fall under SEC reporting rules.

How we can help

Our ReportShield™ quality assurance services give you the ability to demonstrate appropriate controls over your reporting obligations. We can also conduct cross-regulation testing to ensure consistency with other regimes as well as providing remediation of reports.

Accuracy Testing

The testing gold standard, providing the maximum level of protection against regulatory challenge. Learn more

Advanced Regulatory Reconciliation

Our end-to-end reconciliation service tests for the completeness of regulatory reporting. Learn more

Control Framework

Together with data quality, a robust control framework is a key expectation of regulators. Learn more

“It now has been 13 years since Dodd-Frank and well past time for swap dealers to ensure they are in full compliance with the CEA and CFTC regulations. As significant reporting failures continue to persist, our resolutions will reflect the gravity of swap dealers’ continuing failures to prioritize compliance and seek to deter future failures. And when appropriate, we will require a neutral third party to advise, assist with, and test the sufficiency of an entity’s remediation.”

Ian McGinley, Division of Enforcement Director - CFTC – October 2023

External resources

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Further reading

Media
Commentary – CFTC ReWrite marks its first anniversary
Tue 5 Dec, 2023

Commentary – CFTC ReWrite marks its first anniversary
Read more
Blogs
January 2024 – UPI and CFTC ReWrite Phase 2
Tue 17 Oct, 2023

January 2024 – UPI and CFTC ReWrite Phase 2
Read more
Guide
UPI – Unique Product Identifier Explained
Tue 1 Aug, 2023

UPI – Unique Product Identifier Explained
Read more