SEC Security Based Swap 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.

What is SEC SBSR Reporting?

Firms trading OTC derivatives (swaps) 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 Securities Exchange Commission (SEC) oversee the reporting of OTC derivative swaps related to ‘single name’ Credit and Equity securities under the Security Based Swap Reporting (SBSR) portion of the Dodd Frank Act (DFA).

SEC SBSR was originally expected to commence in 2015 but was delayed for several years due to technical and legal issues. SEC Part 45 transaction reporting commenced on 8 November 2021.

SEC Part 43 real-time (public price dissemination – PPD) reporting began on 14 February 2022.

The SEC has a No Action Relief letter in place, instructing SBSR reporting firms to use the CFTC data standards in place at the SDRs. The CFTC has implemented changes, known as the CFTC ReWrite, in December 2022 and this has therefore updated the fields and values being reported to the SEC.

* All other Credit & Equity transactions fall under CFTC reporting rules.

How we can help

Our ReportShield™ quality assurance services give you the ability to demonstrate appropriate controls over your reporting obligations for Parts 43 and 45. We can also conduct cross-regulation testing to ensure consistency with other regimes and provide remediation of reports.