January 2024 – UPI and CFTC ReWrite Phase 2

January 2024 – UPI and CFTC ReWrite Phase 2

The bad news

January 2024 kickstarts a truly tumultuous year for transaction reporting. January 29 more precisely sees the implementation of the CFTC ReWrite Phase 2 which means the adoption of UPI (Unique Product Identifier). After many years in the making the UPI might be having its debutants ball in the USA but that really just gets the ReWrite/Refit party circuit started.

At the time of writing, the calendar for 2024 also entails implementation go-lives for:

Jurisdiction  Regulator Status Description Date
Japan JFSA Confirmed ReWrite 1 April 2024
EU ESMA Confirmed EMIR Refit 29 April 2024
UK FCA Confirmed EMIR Refit  30 September 2024
Australia ASIC Confirmed ReWrite 21 October 2024
Singapore MAS Expected ReWrite “October 2024”
Canada CSA Expected ReWrite Q1 2025
Hong Kong HKMA Expected ReWrite  Q3 2025

The (somewhat) good news

Back in 2015 I wrote an article describing transaction reporting as “the gift that keeps giving”. With eight major implementations planned for next year that’s as true today as it was back then. The 2024/5 reporting ReWrites’ schedule is without a shadow of a doubt the toughest we’ve seen since the inception of OTC derivative transaction reporting. But it’s not all bad news. Challenging as this will be there is some good news. The purpose driving all these implementations is harmonisation and they, for the most part, share a lot in common including the adoption of:

  • UPI to provide a consistent product taxonomy for reporting derivative products
  • CDE (Critical Data Elements) to globally agree the fields, the values and the definitions
  • ISO 20022 XML messaging standards for submitting to trade repositories
  • Global UTI standards to enforce common transaction identifiers across the various reporting regimes.

Therefore the difficulties of managing multiple implementations across various reporting regulations is somewhat offset by the fact the reporting requirements are becoming more standardised and many of the data elements are converging on common globally agreed definitions. Reporting solutions, data dictionaries, analysis and reporting flows in theory become a bit simpler to manage. In theory at least.

What does UPI mean for reporting?

Anyone hoping that reporting with UPIs means simply replacing the current product identifier taxonomies with a new shiny UPI and sitting down with a nice cup of tea is going to be sorely disappointed.

Reporting firms need to map all their current product attributes and then use these attributes to source a UPI from ANNA-DSB for each product. They’ll need to do this for all the product types they currently trade and any open positions previously reported to a trade repository (TR) or swap data repository (SDR).

Some firms may opt to integrate the UPI data in their reporting solution only. Whereas others may integrate it further upstream in their trading, confirmation and associated systems as well. Either way, care will need to be taken to ensure the correct products are mapped to the correct UPIs. Unlike the current simple taxonomies such as FX Forward, the UPI is comparatively opaque and as such it won’t be easy for a human to see if the wrong UPI is on the trade without first looking up the reference data behind that UPI.

Finally, firms will need to take a lot of care to ensure the other fields being reported on any given transaction are consistent with the UPI’s product characteristics. For example, if your UPI relates to a GBP/USD FX Forward then you need to ensure Notional Currency Leg 1&2 also contain GBP & USD.

What does 29 January 2024 look like for CFTC & UPI?

CFTC Rewrite Phase 2 contains two items of good news:

  1. The CFTC descoped UPI for commodity asset class. So UPI is being implemented for credit, equity, FX and interest rates but not commodity
  2. The CFTC also descoped ISO 20022 messaging because they wanted to wait until UPI is also ready for commodities.

Some may argue it’s only postponing the pain as the above postponements will result in a Phase 3, likely in 2025, but for the time being given the evident confusion around UPI, this is probably best for most firms reporting to the CFTC.

Once firms have designed and implemented a functioning UPI process, they will have the joy/pain of ensuring that UPI info is accurately incorporated into regulatory reporting processes given that:

  1. UPI will be required on all* Part 43/PPD submissions to the SDR
  2. UPI will be required on all* Part 45 trade submissions to the SDR
  3. UPI will be required on all Part 45 valuation submissions to the SDR.

*Terminations and Erroring out (Action Types TERM & EROR) will not require UPI for either Part 43 PPD or Part 45 trade submissions. This is to accommodate removing previous submissions that may have been reported prior to UPI being applicable.

Looking at the message specifications for one leading SDR, a handful of previously submittable fields have been deprecated. For example, Underlier ID is no longer required as this information is now embedded within the UPI.

A new paradigm

More interestingly there are fields which will be reported to the CFTC based on data that is derived from the UPI but are not submitted by the reporting firm, such as UPI Status, UPI Instrument Type and UPI Delivery Type. This is essentially a new paradigm for transaction reporting where a range of fields will be sourced from an external data provider (ANNA-DSB) and reported to the regulators despite not being submitted into the SDR by the reporting firm.

This will also impact firms’ control frameworks as they need to ensure that the various product attributes within their systems are aligned to the correct UPI which they’ll submit to the SDR. They’ll also need to consider reconciling fields the SDR derived from the UPI to their source systems despite not having actually submitted these fields.


The CFTC may be the first off the mark with UPI in January next year but there are several other implementations coming, not least for both the EU & UK versions of EMIR. With only four months to go there is a worrying amount of confusion around UPI. Hopefully the UAT process will help to iron out the kinks and figure out the edge cases. Whether UPI achieves the regulatory aims of standardisation and interoperability, time will tell. Meantime 2024 is looking like a doozy for many reporting firms, ourselves at Kaizen included.

  • To understand the fundamentals of UPI, read Alan’s recent guide, UPI Explained
  • Still scratching your head over UPI?  For a conversation with Alan or one of our regulatory specialists, please get in touch