White Paper: The Evolving Challenge of CFTC Reporting

CFTC swap data reporting has improved significantly since the ReWrite went live in 2022. Clearer rules, more stringent validations and more structured reporting have helped remove many obvious errors.

But the data quality challenge hasn’t gone away. 

Many remaining issues are no longer straightforward validation failures. They are valid, accepted and still wrong and this makes them much harder for firms to detect through standard controls.

In this white paper, Alan McIntyre, Kaizen’s North America Reporting Director, explores what Kaizen’s testing data shows about how CFTC reporting issues have evolved, why “valid but wrong” errors persist, and what firms should consider as reporting quality expectations continue to develop.

In this white paper, we cover:

• How CFTC swap data quality has changed before and after the ReWrite
• Why stronger validation has reduced obvious errors but left harder-to-detect issues
• Examples of “valid but wrong” reporting, including timestamps, LEIs, FX rates and population inconsistencies
• Why interpretation drift and system changes can create silent reporting issues
• Why firms may need to rethink how they prioritise remediation.