Congratulations to all of the firms reporting under the CFTC and SEC swap data reporting rules, and of course the SDRs, on the massive achievement implementing the CFTC ReWrite this weekend.
Situated in our unique place in the derivative reporting ecosystem, we know better than most the herculean efforts that go into achieving such a momentous implementation. Personally as someone who has worked twice at a major Trade Repository (TR) I’ve also experienced first-hand the colossal TR exertions that go into implementing a project of such magnitude whilst simultaneously supporting your clients efforts. And here at chez Kaizen we’ve been, let’s say, ‘a wee bit busy’ ourselves supporting our clients and ensuring our own systems’ readiness.
As I’ve been banging on for years now to anyone that would listen, the CFTC ReWrite has been a long time in the making. The CFTC’s 2015 ‘Request For Comment’, led to the 2017 ‘Roadmap to Achieve High Quality Swaps Data’, which in turn led to the new rules and data standards that are finally going live today.
I’ve repeatedly commended the CFTC for its smart adoption of best practices and emerging standard such as the components they’ve modelled based on ESMA’s EMIR framework and global harmonisation workstreams such as CDE. Factor in the onerous ‘Part 49’ requirements to verify, correct or notify on any accuracy or completeness errors and the US regulator’s clear intent to pressure reporting firms into focusing on continually improving data quality, and it’s clear that 5 December 2022 is a monumental day. And not just for CFTC Dodd-Frank reporting and SEC SBSR reporting (which inherits a great deal of the new CFTC ReWrite standards) but for OTC derivative reporting globally as the industry experiences the first major adoption of the CDE standards.
Congratulations to the SDRs, SEFs, DCOs, swap dealers, major swap participants, other reporting firms and of course the CFTC itself, on achieving this huge accomplishment. Now let’s see how that all important data quality is looking and what the relatively near future looks like for the other OTC derivative reporting regimes also adopting CDE.
- For help with any aspect of the new CFTC reporting requirements including Part 49 or for an independent assessment of the quality of your reporting, contact us.