CFTC finally makes the SDR Guidebook public 

The Commodity Futures Trading Commission (CFTC) has quietly made its SDR Guidebook publicly available. Here’s why it matters for anyone reporting under Parts 43 and 45. 

The CFTC has corrected something it got wrong when implementing the ReWrite. It doesn’t sound like much, but it’s both important and useful: it’s finally made its SDR Guidebook public. 

What is the SDR Guidebook? 

The SDR Guidebook (or Guidebook for Parts 43 and 45: Swap Data Reporting and Public Dissemination Requirements for SDRs to give it its fancy, highfalutin title), was previously only available to the SDRs. Which makes sense given the swap data repositories are obviously the intended audience of the guidebook. 

So why should those of us not working at an SDR care about access to the SDR Guidebook? 

Well because the SDR Guidebook contains fields that are not present in the CFTC Technical Specification but are still required to be reported. And this disconnect has required some mental gymnastics for reporting firms. 

Maturity Date Of The Underlier 

This has come up a few times recently in client discussions. 

The Maturity Date Of The Underlier field is not present in the CFTC Tech Spec but is still a reportable field for CFTC Part 45 reporting. This means that firms need to look to their SDR’s message spec (DTCC, KOR, CME or ICE). And this leads to questions like, “if this field isn’t in the CFTC Tech Spec does that mean it’s not as important?” To which the unfortunate answer is, “alas no. It’s definitely a regulatory field.” It’s just that the CFTC muddied the waters by including fields in the SDR Guidebook that are not included in the CFTC Technical Spec. And then compounded this by saying only the SDRs can access the Guidebook. 

Why did the CFTC do this? 

This is where the mental gymnastics really kicks in. You might need to limber up and do some stretches first. 

The CFTC Technical Specification is written from the perspective of UPI being fully implemented. However, UPI was descoped from the original phase 1 December 2022 implementation. And then implemented for 4 out of the 5 asset classes (Commodities being the exclusion) as part of the January 2024 phase 2 implementation. 

This created the gap where fields like Option Type, Delivery Type, Underlier ID are not included in the CFTC Tech Spec because they are considered to be attributes contained within the UPI. But if the UPI is not being reported then these fields must be reported instead. 

Flexible thinking 

Firms therefore need to think flexibly and where there is no UPI, they need to pivot from the CFTC Tech Spec to their trade repository’s Message Spec for those fields. Or where the CFTC has a validation based on a UPI attribute – for example “this field is conditionally required where UPI Delivery Type is Cash”, but there is no UPI – then firms need to pivot to the original Delivery Type data attribute. 

The result – fields buried in a Guidebook firms couldn’t see, with the gap papered over by trade repository specs – has caused confusion.  

The Commission seeing sense and making the guidebook public is therefore a welcome development. 

What else does the guidebook contain? 

If the above wasn’t already super exciting, then brace yourself:

The SDR Guidebook also contains: 

• File Delivery Schedules. Although if you need to know the exact timing of when your data lands on the CFTC’s servers then you must have really messed something up! 

• File Naming Conventions. I told you it was exciting stuff. 

• File Assembly and Compression. You should zip through this section! 

• Connect to CFTC with Secure FTP. Save money on those pesky SDR fees and just send your data directly to the CFTC! Only joking. Do not under any circumstances attempt this. Unless of course you’re an SDR. 

What to actually read 

For those of us that aren’t employed at an SDR it’s section 3.1 and the Data Dictionary for Parts 43 and 45 Files that’s likely to be the useful, and dare I say interesting, part of this document. 

The SDR Guidebook is available here. 

• Download our latest white paper, The Evolving Challenge of CFTC Reporting, where we compare swap data reporting quality before and after the CFTC ReWrite. How does your data compare?