Commodity Futures Trading Commission ♦ Office of Public Affairs ♦ 202-418-5080 

Commodity Futures Trading Commission 

Office of Public Affairs 

Three Lafayette Centre 

1155 21st Street, NW 

Washington, DC 20581 

www.cftc.gov

Procedures to Establish Appropriate Minimum Block Sizes for Large Notional 

Off-Facility Swaps and Block Trades; Further Measures to Protect the

Identities of Parties to Swap Transactions

Questions & Answers

What is the goal of the rulemaking?

The final rulemaking defines the criteria for grouping swaps into separate swap categories and establishes 

methodologies for setting appropriate minimum block sizes for each swap category. The rule sets forth additional 

measures under part 43 of the Commission’s regulations to prevent the public disclosure of the identities, business 

transactions and market positions of swap market participants. The rule is designed to enhance market 

transparency and price discovery by making swap transaction and pricing data available to the public, while also 

protecting the identities, business transactions, and market positions of swap counterparties. 

What does section 2(a)(13) of the CEA require?

Section 727 of the Dodd-Frank Act amends the Commodity Exchange Act (CEA) by inserting a new section 

2(a)(13) which requires the Commission to prescribe regulations specifying what constitutes a large notional swap 

transaction (block trade) for purposes of applying appropriate time delays to reporting such transactions to the 

public. CEA section 2(a)(13) also requires the Commission to consider whether public disclosure of swap 

transaction and pricing data will “materially reduce market liquidity” and prescribe rules that protect the identities of 

counterparties to mandatorily-cleared swaps, swaps excepted from the mandatory clearing requirement and 

voluntarily cleared swaps. CEA section 2(a)(13) further requires the Commission to prescribe rules that maintain 

the anonymity of business transactions and market positions of swap counterparties.

Which swaps are subject to appropriate minimum block sizes?

Unless otherwise determined by the Commission, all publicly reportable swap transactions under the Commission’s 

jurisdiction in all five asset classes (i.e., interest rate, credit, equity, foreign exchange, and other commodity), whether 

cleared or uncleared, and regardless of method of execution (e.g., executed bilaterally, or on a registered swap 

execution facility (SEF) or designated contract market (DCM)) are subject to appropriate minimum block sizes.

What are the “swap categories’ that are being established by the Commission?

For swaps in the interest rate asset class, the rules establish 27 swap categories based on 9 tenor groups and 3 

currency categories (super-major currencies, major currencies, and non-major currencies). For swaps in the credit 
Commodity Futures Trading Commission ♦ Office of Public Affairs ♦ 202-418-5080 

asset class, the rules establish 18 swap categories based 6 tenor groups and three conventional spread groups (0 to 

175 bps, 176 to 350 bps, 351 bps and above). For the FX asset class, the rules establish swap categories based on 

unique currency combinations. For the other commodity asset class, the rules establish swap categories for: (1) 

swaps based on contracts listed in appendix B to part 43 of the Commission’s regulations; (2) swaps that are 

economically related to certain futures contracts; and (3) other swaps sharing a common product type, as designated 

in Appendix D to part 43. All swaps in the equity asset class are grouped into the same category because these 

swaps are not treated as block trades or large notional off-facility swaps. 

Who determines the appropriate minimum block size?

The Commission determines the appropriate minimum block size for all swap categories.

How are the appropriate minimum block sizes calculated?

The final rulemaking implements a two-period, phased-in approach to determining appropriate minimum block 

sizes.

For interest rate and credit swap categories, minimum block sizes in the initial period are determined using a 50 

percent notional amount calculation. In the post-initial period, minimum block sizes are determined using a 67 

percent notional amount calculation.

For most swaps in the FX asset class that are economically related to a futures contract, minimum block sizes in the 

initial period are determined based on the block trade size thresholds set by DCMs. All FX swaps that are not 

economically related to a futures contract can be treated as block trades or large notional off-facility swaps during 

the initial period and are subject to a time delay for public dissemination. In the post-initial period, appropriate 

minimum block sizes for most swaps in the FX asset class will be determined using a 67 percent notional amount 

calculation.

Swaps in the other commodity asset class are subject to appropriate minimum block sizes during the initial period 

based on the following:

 For swaps whose underlying asset references or is economically related to one of the futures contracts listed 

in appendix B to part 43, minimum block sizes in the initial period are determined based on the block sizes 

set for the related contracts by DCMs.

 For swaps whose underlying asset references or is economically related to one of the futures contracts listed 

in appendix B to part 43 that is not subject to a DCM block size minimum, treatment as a block trade or 

large notional off-facility swap is not available.

 For swaps whose underlying asset references or is economically related to one of the futures contracts listed 

in the Commission’s final rulemaking, appropriate minimum block sizes would be determined based on the 

block sizes for the related contracts set by DCMs.

 All other non-futures related swaps (categorized by product type) would be treated as block trades or large 

notional off-facility swaps.

In the post-initial period, appropriate minimum block sizes for all swaps in the other commodity asset class would 

be determined using the 67 percent notional amount calculation.
Commodity Futures Trading Commission ♦ Office of Public Affairs ♦ 202-418-5080 

What are “economically related” swaps?

The final rulemaking defines “economically related” to mean a direct or indirect reference to the same commodity 

at the same location or locations, or with the same or a substantially similar cash market prices series.

What additional contracts does the Commission list in appendix B of part 43?

For purposes of establishing appropriate minimum block sizes for certain swaps in the other commodity asset class, 

the final rulemaking adds 13 natural gas and electricity contracts to the existing 29 futures contracts (which includes 

Brent Crude Oil) in appendix B to part 43 of the Commission’s regulations.

Are swaps in the equity asset class subject to block trade or large notional off-facility swap 

treatment?

All swaps in the equity swap category (in the equity asset class) do not qualify for treatment as a block trade or large 

notional off-facility swap and, therefore, are not subject to a time delay for public dissemination.

How will the appropriate minimum block sizes be implemented?

All initial appropriate minimum block sizes (listed by asset class and swap category in appendix F to part 43) would 

be effective 60 days following the publication in the Federal Register of the final rule. The initial period – which 

would last until the Commission and SDRs have collected a year of reliable data (April 10, 2014) – would expire 

following the Commission’s publication of post-initial appropriate minimum block sizes. Post-initial appropriate 

minimum block sizes would become effective on the first day of the second month following the date of their 

publication.

How does a phased-in approach to implementing appropriate minimum block sizes benefit 

market participants?

The Commission anticipates that a two-period approach to implementing appropriate minimum block sizes, in 

addition to the interim period established by the real-time reporting final rule, will allow market participants to 

better adjust their swap trading strategies to manage risk, secure new technologies and make necessary arrangements 

to comply with part 43 of the Commission’s regulations.

How do market participants obtain information about appropriate minimum block sizes?

Appendix F to part 43 lists the initial appropriate minimum block sizes by asset class and swap category. The 

Commission will publish the post-initial appropriate minimum block sizes on the Commission’s website and would 

publish updated block sizes thereafter in the same manner no less than once each calendar year.

How do parties to a swap notify of their election for block trade or large notional off-facility 

swap treatment?

For publicly reportable swap transactions with a notional amount at or above an appropriate minimum block size, 

the parties to the transaction are required to notify the registered SEF or DCM of its election to have their 

transaction treated as a block trade. The SEF or DCM would then notify the registered SDR of this election when 

submitting swap transaction and pricing data.
Commodity Futures Trading Commission ♦ Office of Public Affairs ♦ 202-418-5080 

A reporting party who executes a large notional off-facility swap with a notional amount at or above an appropriate 

minimum block size is required to notify the applicable registered SDR of its election to have the transaction treated 

as a large notional off-facility swap.

How are notional cap sizes determined under the proposed rules?

In the initial period, cap sizes are set as the greater of the interim cap sizes set forth under part 43 of the 

Commission’s regulations or the appropriate minimum block size for the respective swap category. If an 

appropriate minimum block size does not exist, then the cap size will be set at the interim cap size. In the postinitial period, the proposed rules establish a 75 percent notional amount calculation to determine cap sizes for the 

respective swap categories. 

What limits do the proposed rules establish for public dissemination of certain swap 

transactions in the other commodity asset class with a specific delivery or pricing 

point?

For swaps that have natural gas or related products as an underlying asset and a specific delivery or pricing point in 

the United States, SDRs will publicly disseminate a description of the specific delivery or pricing point based on one 

of the five industry-specific natural gas markets set forth by the Federal Energy Regulatory Commission. For swaps 

that have petroleum products as an underlying asset and a specific delivery or pricing point in the United States, 

SDRs will publicly disseminate a description of the specific delivery or pricing point based on one of the seven 

Petroleum Administration for Defense Districts regions. For swaps that have electricity and sources as an 

underlying asset and have a specific delivery or pricing point in the United States, SDRs will publicly disseminate a 

description of the specific delivery or pricing point based on a description of one of the North American Electric 

Reliability Corporation regions for publicly disseminating for publicly disseminating delivery or pricing points for 

electricity swaps.