CFTC (Dodd-Frank) 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.

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What is CFTC Reporting?

Firms trading OTC derivatives 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 Commodities and Futures Commission (CFTC) oversees the reporting which includes all other OTC derivatives for Credit*, Equity*, FX, Interest Rates and Commodities asset classes.

CFTC reporting commenced in 2013 with DTCC, CME and ICE operating SDRs.

The CFTC Rewrite and Part 49 requirements

A substantial revision of the reporting rules, known as the CFTC ReWrite, went live in December 2022.

The rewrite also introduced the so-called “Part 49” requirements around verification (of the completeness and accuracy of a firm’s reporting), corrections and notification to the CFTC when a firm cannot perform the timely corrections.

UPI (Unique Product Identifier) was adopted in January 2024 for Credit, Equity, FX and Interest Rates asset classes. UPI adoption for Commodities is currently unscheduled.

*Certain Credit and Equity transactions fall under SEC reporting rules.

How we can help

Our ReportShield™ quality assurance services give you the ability to demonstrate appropriate controls over your reporting obligations. We can also conduct cross-regulation testing to ensure consistency with other regimes as well as providing remediation of reports.

Accuracy Testing

The testing gold standard, providing the maximum level of protection against regulatory challenge. Learn more

Completeness Controls

Our Completeness Controls tool provides comprehensive, independent end-to-end reconciliation Learn more

Control Framework

Together with data quality, a robust control framework is a key expectation of regulators. Learn more

“It has been 13 years since Dodd-Frank and well past time for swap dealers to ensure they are in full compliance with the CEA and CFTC regulations. As significant reporting failures continue to persist, our resolutions will reflect the gravity of swap dealers’ continuing failures to prioritize compliance and seek to deter future failures.”

Ian McGinley, Division of Enforcement Director - CFTC – October 2023

External resources

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Is your CFTC reporting accurate and complete?

For a conversation with one of our regulatory specialists, please get in touch.

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