U.S. COMMODITY FUTURES TRADING COMMISSION

Three Lafayette Centre 

1155 21st Street, NW, Washington, DC 20581 

Telephone: (202) 418-5260 

Facsimile: (2 ) 418-5527

Office of the Chief 

Economist

02

 August 5, 2011 

Dear Subcommittee members, 

 Thank you very much for agreeing to serve on the Subcommittee of Data Standardization 

of the CFTC Technology Advisory Committee. 

 Today we have the first public meeting of the subcommittee here at the CFTC. According 

to the agenda that you all have, we will begin with the opening remarks, statements and brief 

introductions; then members on each of the four working groups will have a chance to discuss 

issues, projects, and deliverables; and at the end we will gather together again to summarize the 

results of today’s work. 

 Attached to my remarks is a list of issues and possible deliverables for each working 

group. These are suggestions to get us all started. Each working group will ultimately draw on 

the expertise of its members when deciding what issues to tackle and what end product to deliver 

to the Technology Advisory Committee. 

 For example, for a particular issue within your workgroup, you may advise that a 

regulatory action is needed and describe what that action might be. Or you may advise that 

regulatory oversight of ongoing private processes would be best, or that no practicable solution 

to the issue is at hand. You may also wish to flag and consider other issues not on this list but 

within the topic scope of your workgroup. 

 In considering your recommendations, please keep in mind the general goals of 

promoting market stability and efficiency, increasing transparency, removing barriers to entry at 

various industry levels, and avoiding unduly burdensome transition costs or requirements. The 

Technology Advisory Committee, and ultimately the Commodity Futures Trading Commission, 

approaches these issues with an open mind and welcomes the private/public partnership 

demonstrated by your participation on this important subcommittee. 

Just as a reminder, the next meeting dates will be Friday, September 30, 2011 from 1 pm to 4 pm 

and Friday, November 4, 2011 from 1 pm to 5 pm. 

 Let’s get to work! 

 

Cordially, 

Andrei Kirilenko 

Chief Economist, CFTC 

Chair, TAC Subcommittee on Data Standardization
Group 1 Product and Entity Identification

The issue: 

 There is currently no widely accepted standardized list for product and entity 

identification, although there are industry efforts underway in coordination with the international 

community. Use of such identifiers assist in the greater consistency in the collection, reporting, 

and management of individual transactions and mitigation of systemic risk. 

 Beyond and part from existing CFTC rulemakings, such as 17 CFR Part 45 Swap Data 

Recordkeeping and Reporting Requirements

(http://www.cftc.gov/ucm/groups/public/@lrfederalregister/documents/file/2010-30476a.pdf), 

and related SEC rulemakings, there is a public and private need for greater standardization. 

Proposed deliverables: 

Beyond these existing rulemakings, what role can/should government regulators take in 

setting the timetable for completion of a standard list and obtaining/mandating consensus on 

standardized product and entity identifiers in the swaps market? Input on mechanisms through 

which these identifiers will be issued. 

 How can standardization be coordinated with international organizations and 

governmental practice without unduly delaying progress? 

 Analysis of how standardization in this area could be designed to minimize transition 

costs by not requiring pre-existing business practices to switch to different markup languages. 

Membership:

 Eric Chacon, Global Head of Data Standards, Citigroup 

 Neil Chinai, Managing Director of Technology, Barclays Capital 

 RJ Cummings, VP Product Development, ICE 

 Bob Green, Vice President, DTCC 

 Marlene McMahon, Senior Business Manager, SWIFT Americas 

 Brian Okupski, Director, Head of Reference Data Business, Markit 

Working Group Co-Coordinators: 

Andy Thatai, Data Architect, CFTC Office of Information Technology 

Bill Nichols, Associate Director Information Standards, Office of Financial Research, 

U.S. Treasury 

 
Group 2 Machine-Readable Legal Documents

The issue: 

 Pursuant to Section 719(b) of Dodd-Frank, the SEC and CFTC prepared and submitted to 

Congress this April 2011a Joint Study on the Feasibility of Mandating Algorithmic Descriptions 

for Derivatives. See http://www.cftc.gov/pressroom/pressreleases/pr6017-11.html. One of the 

key conclusions of that study was that the economic and legal terms of a derivatives contract, 

including lifecycle events, could be and should be machine-readable. This is technologically 

achievable. 

Proposed deliverables: 

 Recommendations on how and when standardized machine-readable legal documents can 

be created for most complex swaps, including ISDA master agreements and collateral 

documents. 

 Recommendations on how much machine-readable data can be standardized for 

regulatory oversight or delivery to swap data repositories. 

 Recommendations on whether, how, and when data on lifecycle events can be captured 

and analyzed by regulators to analyze net exposures in the market. 

 Any recommendations on how to standardize bespoke products for machine-readability. 

 Comments on or recommendations on how to implement Section 719(b) study 

recommendations concerning machine-readable documents. 

Membership: 

 

 Michael A. Will, Founder and Chief Technology Officer, docGenix 

 Pierre Lamy, VP Global Derivatives Technology Group, Goldman Sachs 

 Paulo Rodela, Managing Director, BlackRock Solutions 

 Working Group Coordinator:

 Nancy R. Doyle, Assistant General Counsel, CFTC 

 
Group 3 Semantic Representation of Financial Instruments

The issue: 

 Pursuant to Section 719(b) of Dodd-Frank, the SEC and CFTC prepared and submitted to 

Congress this spring a Joint Study on the Feasibility of Mandating Algorithmic Descriptions for 

Derivatives. 

 There is a need and desire to go beyond legal entity identifiers and lay the foundation for 

universal data terms to describe transactions. 

Proposed deliverables: 

 How to achieve consensus among varying private industry approaches to this issue? 

 What is a proposed timeline for achieving semantic representation and taxonomy with 

realistic milestones? 

 How to coordinate internationally with any domestic regulatory initiatives or 

partnerships? 

Membership: 

 Michael Atkin, Managing Director, Enterprise Data Management Council 

 Karel Engelen, Director and Global Head Technology Solutions 

 Timothy J. McHenry, Director, Information Services, NFA 

 Karla McKenna, Chairperson of TC68, ISO 

 James Woods, Chief Technology Officer, FIA Technology Services, Inc. 

Working Group Coordinator:

 JonMarc Buffa, Senior Trial Attorney, CFTC Division of Enforcement 

 
Group 4 Storage and Retrieval of Financial Data

The issue: 

 Large amounts of data will be arriving in the swap depositories. 

http://www.cftc.gov/ucm/groups/public/@lrfederalregister/documents/file/2010-31133a.pdf (17 

CFR Part 49 Swap Data Repositories). There is a tremendous need for efficiency in design of 

data storage, transfer, and analysis in a standardized format. Particularly for regulatory reporting 

and real-time reporting, but also for internal business use, standardization in the treatment of this 

data is an important common goal of public and private sectors. Beyond and apart from this and 

other rules or rulemaking proceedings,1 what public, private, or public/private partnered 

initiatives can be undertaken to obtain greater standardization while ensuring privacy of data 

(including PPI) and minimizing transition costs? 

Proposed deliverables: 

 How to best achieve this goal on a reasonable time frame, with analysis of transitions 

costs? 

 Specific analysis of what can be easily standardized now (low-hanging fruit) and 

description of longer-range goals for standardization and how they can be achieved? 

What elements of the storage, transfer, and retrieval of financial data could or should be 

open-sourced? 

 

 

 Without discussion of specific software or hardware products, what types of designs and 

technological approaches will best integrate reporting to SDRs with real-time use and analysis of 

market data by market participants and regulators? 

Membership:

 Marc Donner, Engineering Director, Google, Inc. 

 Samuel H. Gaer, CIO and EVP, Business Services, FINRA 

 Adam Litke, Chief Risk Strategist, Bloomberg LP 

James Moran, Global Director, Market Regulation Technology & Strategy, CME Group 

Peter Marney, Senior VP, Content Marketplace, Thomson Reuters 

Working Group Coordinator:

Andrei Kirilenko, Chief Economist and Data Standardization Subcommittee Chair, CFTC 

1

 E.g., 17 CFR Part 45 Swap Data Recordkeeping and Reporting Requirements: 

http://www.cftc.gov/ucm/groups/public/@lrfederalregister/documents/file/2010-30476a.pdf, and

17 CFR Part 43 Real-Time Public Reporting of Swap Transaction Data: 

http://www.cftc.gov/ucm/groups/public/@lrfederalregister/documents/file/2010-29994a.pdf.