Large Trader Reporting for Physical Commodity Swaps:

Division of Market Oversight Guidebook for Part 20 Reports

AS OF 6/22/2015

ALL PRIOR VERSIONS ARE OBSOLETE

U.S. COMMODITY FUTURES TRADING COMMISSION

Division of

Market Oversight
Page 2

Table of Contents:

I. Overview

II. Part 20 Guidance

a. Data Dictionary for Section 20.3(b) Data Elements – Clearing Organizations

b. Data Dictionary for Section 20.3(c) Data Elements – Clearing Organizations

c. Data Dictionary for Section 20.4(c) Data Elements – Reporting Entities

d. Notes on Commodity Reference Prices

e. Notes on Reporting Data Records Associated with Basis Swaps, Inter-Commodity Spread Swaps, Commodity Index Swaps, and 

Calendar Spread Swaps

f. Notes on Index Definition and Diversified Commodity Indices

g. Notes on Non-Standard Options

i. Use of the Non-Standard Swaption Indicator

ii. Reporting Positions from Swaption Transactions with a Non-Standard Strike Price

h. Notes on the Execution Facility Indicator

i. Notes on the 102S Filing

j. Paired Swaps: Guidelines for Linkage to §20.2 Contracts

k. Notes on Notional Value

l. Futures Equivalency Guidelines

i. Swaps linked to a DCM Contract

ii. Swaps not linked to a DCM contract

iii. Price Reference Month

iv. Daily and Weekly Swaps

v. Average Price Swaps

vi. Variance and Volatility Swaps

m. Notes on the Manner of Reporting

III. Data Record Layout Examples

Data Records 1-3 (Swaps A, B, C)

Data Records 4-9 (Swap D)

Data Records 10-11 (Swap E)

Data Records 12-17 (Swaps F, G, H) 

Data Records 18-19 (Swap I)

Data Records 20-25 (Swap J)
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Data Records 26-27 (Swap K)

Data Records 28-52 (Swaps A, B, C, D, E, F, G, H, I, J)

Data Records 53-70 (Swap J)

Data Records 71-78 (Swap L)

Data Records 79-102 (Swap M)

Data Records 103-106 (Swap N)

Data Records 107-110 (Swap O)

Data Records 111-120 (Swap P) 

IV. Swap Transaction Examples

V. Technical Requirements

a. Formats

i. File Format for Part 20

ii. Mapping of Part 20 to FpML

b. Electronic Data Transmission Procedures

i. Formatting Data for Transmission

ii. Assembly and Compression

iii. Secure FTP Account Registration

iv. File Transmission

c. Technical Support

VI. Appendices

Appendix A: Covered Futures Contracts and Underlying Commodity Codes

Appendix B: Reserved

Appendix C: Layout for Open Interest file

Appendix D: Layout for 102S Filing Submission

Appendix E: Part 20 Reporting Scenarios 

Note: Appendices F through U have been moved to a separate document titled “Guidebook for Part 20 Appendix Schemas”.
Page 4

I. Overview

On July 22, 2011, the Commodity Futures Trading Commission (“Commission” or “CFTC”) published large trader reporting rules for 

physical commodity swaps and swaptions (76 FR 43851). The reporting rules became effective on September 20, 2011 and are codified in 

new Part 20 of the Commission’s regulations.

1

 Section 20.3 of the reporting rules requires daily reports from clearing organizations. Section 

20.4 of the reporting rules requires daily reports from clearing members and swap dealers. Clearing members that are required to provide § 

20.4 reports are those entities that are authorized by a clearing organization to clear one or more paired swaps as that term is defined in § 20.1 

and as described in this Guidebook (regardless of whether the entity actually does clear such swaps). Reporting entities are required to report 

inter-affiliate transactions under Part 20 if they are separate legal entities. 

Notably, § 20.1 defines a swaption as an option to enter into a swap or a swap that is an option. Therefore, both options to enter into swaps 

and swaps that are options may be reportable as paired swaps under Part 20. Swaps that come within the definition of a paired swap, as that 

term is defined in § 20.1 and as described in this Guidebook, solely by being linked to any Brent Crude Oil Commodity Reference Price

(“CRP”), are not required to, but may voluntarily, be reported to the Commission until further notified by the Division. 

Pursuant to §§ 20.7 and 20.8, this Guidebook in part establishes the form and manner of reporting and submitting information to the 

Commission.

2

 1 On September 16, 2011, the Division issued a letter under Section 20.10(c) to conditionally relieve clearing organizations and clearing members from the reporting 

requirements of Sections 20.3 and 20.4 until November 21, 2011 for cleared swaps, and January 20, 2012 for uncleared swaps. On November 18, 2011, the Division 

issued a letter under Section 20.10(c) to establish a conditional safe harbor that permitted less than fully compliant reporting by clearing orgnizations and clearing 

members under Sections 20.3 and 20.4 until March 20, 2012. On March 20, 2012, the Division issued a letter providing conditional no-action relief to clearing 

organizations and clearing members from less than fully compliant reporting under Sections 20.3 and 20.4 until July 2, 2012. On July 17, 2012, the Division issued a 

letter providing conditional no-action relief from the reporting requirements of Section 20.4 to swap dealers that were not clearing members (“non-clearing member swap 

dealers”), until 60 days after the “swap dealer registration application date” (as defined in such letter), and on December 14, 2012 the Division extended this no-action 

relief until March 1, 2013. The July 17, 2012 and December 14, 2012 letters also provided non-clearing member swap dealers that satisfied certain conditions with an 

additional six calendar months of reporting relief; this additional relief expired on September 1, 2013. On December 21, 2012, the Commission approved an order which, 

among other things, permitted non-U.S. swap dealers that were not part of an affiliated group in which the ultimate parent entity was a U.S. swap dealer, U.S. major swap 

participant, U.S. bank, U.S. financial holding company or U.S. bank holding company to delay compliance with the reporting requirements of Part 20, solely for swaps 

with their non-U.S. counterparties, until July 12, 2013. In addition to the foregoing relief, the Division has also issued conditional and time-limited no-action relief from 

certain specific reporting requirements of Part 20. Copies of the letters and orders providing all of the above-described relief are available on the Commission’s website at 

http://www.cftc.gov/LawRegulation/DoddFrankAct/Rulemakings/XXXII.LargeSwapsTraderReporting/index.htm. 

2 This Guidebook is issued pursuant to, and does not exceed, the Commission delegated authority in regulation 20.8. 
Page 5

XML-based file formats for Part 20 reports include the FpML Exposure Report and the FIXML Position Report. Section VI, the Technical 

Requirements section of this Guidebook, includes detailed information on creating and transmitting Part 20 reports to the CFTC through the

XML schemas mentioned above. This Guidebook also supplements Appendix A to Part 20 and provides instructional guidelines for 

calculating futures equivalent swaps positions. 

Sections 20.7(b) and (c) provide the daily timing for the submission of the Part 20 reports. Clearing organizations must submit reports no 

later than 9:00 a.m. eastern time on the next business day following the reporting day as that term is defined in § 20.1. Clearing members and 

swap dealers must report no later than 12:00 p.m. eastern time on the second (T+2) business day following the reporting day to which the 

information pertains. For example, clearing organizations will provide reports for reporting day November 21 on November 22 and clearing 

members and swap dealers will provide reports for reporting day November 21 on November 23, 2011.
Page 6

II. Part 20 Guidance

The tables below show the data elements that are to be included in § 20.3 and § 20.4 reports, a description of each data element, valid values 

for the data element, and code for that data element for the FpML Report and FIXML Report. Note that the code provided is intended to be 

only a partial example of acceptable FpML and FIXML schemas. Section III of this Guidebook provides example Part 20 data records.

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas”, contain complete FpML and 

FIXML schemas for these example data records.

a. Data Dictionary for Section 20.3(b) Data Elements: Clearing Organizations

(1) An identifier assigned by the Commission to the clearing organization;

(2) The identifier assigned by the clearing organization to the clearing member;

(3) The identifier assigned by the clearing organization for a cleared product;

(4) The reporting day;

(5) A proprietary or clearing member customer account indicator;

(6) The futures equivalent month;

(6)(i) Price reference month;

(7) The commodity reference price;

(7)(i) Position type indicator;

(8) Gross long swap positions;

(9) Gross short swap positions;

(10) A swaption put or call side indicator;

(11) A swaption expiration date; 

(12) A swaption strike price;

(12)(i) Non-standard swaption indicator;

(13) Gross long non-delta-adjusted swaption positions; and

(14) Gross short non-delta-adjusted swaption positions.
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 7

Data Element CFTC Description, Purpose or Instruction FpML* FIXML*

(1) An identifier assigned by the Commission to 

the clearing organization

An identifier for each swaps clearing 

organization, assigned by the CFTC. The list 

of identifiers may change/expand over time.

exposureReport/onBehalfOf/partyReference@

href

(where partyReference@href = party@id)

exposureReport/party@id

exposureReport/party/partyId

exposureReport/party/partyName

Valid values:

CME = CME Clearing House

ICUS = ICE Clear US

ICEU = ICE Clear Europe

LCH = LCH.Clearnet

NGX = Natural Gas Exchange

PosRpt:Pty@ID=[Clearing Org ID]

PosRpt:Pty@Src=M

PosRpt:Pty@R=21

Valid values:

CME = CME Clearing House

ICUS = ICE Clear US

ICEU = ICE Clear Europe

LCH = LCH.Clearnet

NGX = Natural Gas Exchange

(2) The identifier assigned by the clearing 

organization to the clearing member

An unique identifier for each clearing member 

of a clearing organization, assigned by that 

clearing organization. Members may have 

multiple ID's assigned by multiple clearing 

organizations.

exposureReport/exposure/relatedParty/partyRe

ference@href

(where partyReference@href = party@id) 

exposureReport/exposure/relatedParty/role='C

ounterParty' 

exposureReport/party@id

exposureReport/party/partyId

exposureReport/party/partyName

PosRpt:Pty@ID=[102S Identifier]

PosRpt:Pty@Src= D

PosRpt:Pty@R=4

(3) The identifier assigned by the clearing 

organization for a cleared product

A unique identifier for each cleared product 

that is assigned by the clearing organization. If 

the clearing code and commodity code are 

different, both must be provided.

exposureReport/exposure/

productId[@productIdScheme='clearing_org_p

roduct_code']

PosRpt:Instrmt@ID=[Cleared Product ID]

PosRpt:Instrmt@Src=H

if commodity code is different:

PosRpt:PosUnd:Undly:AID@AltID=[Commod

ity code]

PosRpt:PosUnd:Undly:AID@AltIDSrc=M

(4) The reporting day Identifies the day for which the records pertain 

(i.e. closing of books or valuations) or at the 

closing of the trading session. Includes the 

date, time and timezone offset.

exposureReport/asOfDate 

exposureReport/asOfTime

Valid formats:

YYYY-MM-DD

hh:mm:ss[+/-]hh:mm

PosRpt@BizDt=[YYYY-MM-DD]

PosRpt@TxnTm=[YYYY-MMDDThh:mm:ss[+/-]hh:mm]

Valid formats:

YYYY-MM-DD

YYYY-MM-DDThh:mm:ss[+/-]hh:mm

 
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 8

Data Element CFTC Description, Purpose or Instruction FpML* FIXML*

(5) A proprietary or clearing member customer 

account indicator

Designate as house or customer position. exposureReport/exposure/category

Valid values:

"House";

"Customer"

PosRpt:Pty@ID=[H, C]

PosRpt:Pty@Src=D

PosRpt:Pty@R=38

Valid values:

H = House

C = Customer

(6) The futures equivalent month Corresponds to the price exposure resulting 

from the swap. The futures equivalent 

positions generated from a swap would be the 

portfolio of futures contracts that would most 

closely provide the price exposure of that 

swap. The format may include days.

exposureReport/exposure/futuresEquivalentMo

nth

Valid formats:

YYYY-MM or 

YYYY-MM-DD

PosRpt:PosUnd:Undly@MMY=[YYYYMMD

D]

Valid formats:

YYYYMM or 

YYYYMMDD

(6)(i) Price reference month The calendar month exposure resulting from 1) 

a situation where a paired swap does not 

reference a DCM contract in §20.2 and the 

delivery of the instruments comprising the cash 

market index used for pricing does not 

coincide with any delivery window of a 

relevant DCM contract; or, 2) any exposure 

reported as part of a paired swap but which is 

not in any of the commodities (or substantially 

the same commodities) underlying the DCM 

contracts listed in § 20.2. The price reference 

month should, by definition, only be reported 

when there is not an applicable futures 

equivalent month for the position being 

reported. The format provided should be year 

and month only.

exposureReport/exposure/priceReferenceMont

h

Valid formats:

YYYY-MM

PosRpt:PosUnd:Undly@PxRefMo=[YYYYM

M]

Valid formats:

YYYYMM

(7) The commodity reference price CRP refers to the term as defined in SubAnnex A of the 2005 ISDA Commodity 

Definitions, or to any subsequent versions of 

that document. CRPs are discussed further in 

this Guidebook.

exposureReport/exposure/underlyingAsset/co

mmodity/instrumentId[contains(@instrumentId

Scheme, ‘commodity-reference-price’)]

PosRpt:PosUnd:Undly@ID=[Commodity 

reference price code]

PosRpt:PosUnd:Undly:AID@AltIDSrc= [R]

Valid value:

R = ISDA Commodity Reference Price

(7)(i) CRP position type indicator Additional information related to the pricing of 

the swaps position, specifically an indicator 

referring to the position type as defined below 

in the Guidebook. Position Type Indicators 

should be populated with one of the four 

options for each reportable swap and swaption 

position.

exposureReport/exposure/exposureType

Valid values:

“TwoComponentIntercommoditySpread”;

“IndexOrBasket”;

“TwoComponentLocationalBasis”;

“Other”

PosRpt@ConRefPosTyp=[0, 1, 2, 99]

Valid values:

0 = Two component intercommodity spread

1 = Index or basket

2 = Two component locational basis

99 = Other
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 9

Data Element CFTC Description, Purpose or Instruction FpML* FIXML*

(8) Gross long swap positions For cleared, state number of gross long futures 

equivalent contracts that make up the targeted 

contract. Format: decimal (4). If the position is 

reported in units other than contracts, include 

the units or currency. If the position is reported 

in terms of a currencyinclude ISO currency 

code.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType=

'LongSwapPosition' 

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=GRS

PosRpt:Qty@Long=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, g, 

Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, kWd, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

Valid values:

GRS = Gross paired swap position

(9) Gross short swap positions For cleared, state number of gross short futures 

equivalent contracts that make up the targeted 

contract. Format: decimal (4). If the position is 

reported in units other than contracts, include 

the units or currency. If quote is reported in 

terms of a currency, include ISO currency 

code.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType=

'ShortSwapPosition' 

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=GRS

PosRpt:Qty@Short=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, g, 

Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, kWd, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

Valid values:

GRS = Gross paired swap position

(10) A swaption put or call side indicator Put indicates a long or short put. Call indicates 

a long or short call.

exposureReport/exposure/optionType

Valid values:

“Put”;

“Call”;

“ “ (null)

PosRpt:Instrmt@PutCall=[0,1]

Valid values:

0 = Put 

1 = Call

(11) A swaption expiration date Indicates the year, month and day when the 

swaption expires

exposureReport/exposure/expirationDate

Valid formats:

YYYY-MM-DD

PosRpt:Instrmt@MMY=[YYYYMMDD]

Valid formats:

YYYYMMDD

(12) A swaption strike price Strike price of swaption, using pricing 

convention of contract. Includes currency 

(native) and unit and decimal. Use ISO 

currency code to report currency. Reported in 

dollars, not cents. Values can be negative. 

Format: decimal (4)

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType=

'StrikePrice' 

exposureReport/exposure/quote/quoteUnit 

exposureReport/exposure/quote/currency

PosRpt:Instrmt@StrkPx=[decimal number]

PosRpt:Instrmt@StrkCcy=[ISO Currency 

Code]

PosRpt:Instrmt@StrkUOM=[Alw, Bbl, Bcf, 

BDFT, Bu, CBM, Ccy, CDD, CER, CPD, 

CRT, cwt, day, dt, EnvAllwnc, EnvCrd, 

EnvOfst, FEU, g, Gal, GJ, GT, HDD, IPNT, 

kg, kL, kW-a, kW-d, kWh, kW-h, kW-M, kWmin , L, lbs, MMBtu, MW-a, MW-d, MWh, 

MW-h, MW-M, MW-min, oz_tr, PRINC, t, 

TEU, thm, tn]
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 10

Data Element CFTC Description, Purpose or Instruction FpML* FIXML*

(12)(

i)

Non-standard swaption indicator An indicator that identifies non-standard 

swaptions. See section II.g ‘Notes on NonStandard Options’ of this Guidebook for 

circumstances when a swaption would be 

considered non-standard. 

exposureReport/exposure/productType

Valid values:

“Standard”;

“NonStandard”;

“ “ (null)

PosRpt/Instrmt@SecTyp=[SWAPTION ]

PosRpt/Instrmt@SubTyp=[S, N]

Valid values:

SWAPTION = Swaption as defined in § 20.1

Valid values:

S=Standard

N=NonStandard

(13) Gross long non-delta-adjusted swaption 

positions

For cleared, state number of gross long nondelta adjusted futures equivalent contracts. 

Format: decimal (4). If the position is reported 

in units other than contracts, include the units 

or currency. If the position is reported in terms 

of a currency, inclue ISO currency code.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType=

'NonDeltaAdjustedLongSwaptionPosition'

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=NDAS

PosRpt:Qty@Long=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, g, 

Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, kWd, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

Valid values:

NDAS = Gross non-delta-adjusted swaption 

position

(14) Gross short non-delta-adjusted swaption 

positions

For cleared, state number of gross short nondelta adjusted futures equivalent contracts. 

Format: decimal (4). If the position is reported 

in units other than contracts, include the units 

or currency. If the position is reported in terms 

of a currency, include ISO currency code.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType=

'NonDeltaAdjustedShortSwaptionPosition'

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=NDAS

PosRpt:Qty@Short=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, g, 

Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, kWd, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

Valid values:

NDAS = Gross non-delta-adjusted swaption 

position
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 11

b. Data Dictionary for Section 20.3(c) Data Elements: Clearing Organizations

For all futures equivalent months, clearing organizations shall report end of reporting day settlement prices for each cleared product and 

deltas for every unique swaption put and call, expiration date, and strike price. 

Data Element CFTC Description, Purpose or Instruction FpML* FIXML*

(1) Reporting day Identifies the day for which the records pertain 

(i.e. closing of books or valuations) or at the 

closing of the trading session. Includes the 

date, time and timezone offset.

exposureReport/asOfDate 

exposureReport/asOfTime

Valid formats:

YYYY-MM-DD

hh:mm:ss[+/-]hh:mm

PosRpt@BizDt=[YYYY-MM-DD]

PosRpt@TxnTm=[YYYY-MMDDThh:mm:ss[+/-]hh:mm]

Valid formats:

YYYY-MM-DD

YYYY-MM-DDThh:mm:ss[+/-]hh:mm

(2) Futures Equivalent Month Provide the native contract’s expiration date. exposureReport/exposure/futuresEquivalentMo

nth

Valid formats:

YYYY-MM

YYYY-MM-DD

PosRpt:PosUnd:Undly@MMY=[YYYYMMD

D]

Valid formats:

YYYYMM

YYYYMMDD

(3) Settlement price The recognized price by that clearing 

organization for that cleared product on that 

trading day. Values can be negative. Use ISO 

currency code.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType=

'SettlementPrice' 

exposureReport/exposure/quote/quoteUnit 

exposureReport/exposure/quote/currency

PosRpt@SetPx=[decimal number]

PosRpt@SetPxUOMCcy=[ISO Currency 

Code]

PosRpt@SetPxUOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, g, 

Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, kWd, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

(4) Cleared product identifier A unique identifier for each cleared product 

that is assigned by the clearing organization. If 

the clearing code and commodity code are 

different, both must be provided.

exposureReport/exposure/

productId[@productIdScheme='clearing_org_p

roduct_code']

PosRpt:Instrmt@ID=[Cleared Product ID]

PosRpt:Instrmt@Src=H 

if commodity code is different:

PosRpt:PosUnd:Undly:AID@AltID=[Commod

ity code]

PosRpt:PosUnd:Undly:AID@AltIDSrc=M

(5) Swaption put or call side indicator Put indicates a long or short put. Call indicates 

a long or short call.

exposureReport/exposure/optionType PosRpt:Instrmt@PutCall=[0,1]

 
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 12

Data Element CFTC Description, Purpose or Instruction FpML* FIXML*

Valid values:

“Put”;

“Call”;

“ “ (null)

valid values:

0 = Put 

1 = Call

(6) Swaption expiration date Indicates the year, month and day when the 

swaption expires

exposureReport/exposure/expirationDate

Valid formats:

YYYY-MM-DD

PosRpt:Instrmt@MMY=[YYYYMMDD]

Valid formats:

YYYYMMDD

(7) Swaption strike price Strike price of swaption, using pricing 

convention of contract. Includes currency 

(native) and unit and decimal. Use ISO 

currency code to report currency. Reported in 

dollars, not cents. Values can be negative. 

Format: decimal (4)

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType=

'StrikePrice' 

exposureReport/exposure/quote/quoteUnit 

exposureReport/exposure/quote/currency

PosRpt:Instrmt@StrkPx=[decimal number]

PosRpt:Instrmt@PxUOMCcy=[ISO Currency 

Code]

PosRpt:Instrmt@PxUOM=[Alw, Bbl, Bcf, 

BDFT, Bu, CBM, Ccy, CDD, CER, CPD, 

CRT, cwt, day, dt, EnvAllwnc, EnvCrd, 

EnvOfst, FEU, g, Gal, GJ, GT, HDD, IPNT, 

kg, kL, kW-a, kW-d, kWh, kW-h, kW-M, kWmin , L, lbs, MMBtu, MW-a, MW-d, MWh, 

MW-h, MW-M, MW-min, oz_tr, PRINC, t, 

TEU, thm, tn]

(8) Swaption delta factor The factor used by the Clearing Organization 

to convert the gross options into delta-adjusted 

positions. Format: decimal (4)

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType=

'DeltaFactor'

PosRpt@PxDelta=[decimal number]

(9) Clearing organization identifier An identifier for each swaps clearing 

organization, assigned by the CFTC. Clearing 

organization should use previously assigned ID 

if exists. The list of identifiers may 

change/expand over time.

exposureReport/exposure/relatedParty/partyRe

ference@href

(where partyReference@href = party@id) 

exposureReport/exposure/relatedParty/role='Cl

earingOrganization' 

exposureReport/party@id

exposureReport/party/partyId

exposureReport/party/partyName

Valid values:

CME = CME Clearing House

ICUS = ICE Clear US

ICEU = ICE Clear Europe

LCH = LCH.Clearnet

NGX = Natural Gas Exchange

PosRpt:Pty@ID=[Reporting ID]

PosRpt:Pty@Src=M

PosRpt:Pty@R=21

Valid values:

CME = CME Clearing House

ICUS = ICE Clear US

ICEU = ICE Clear Europe

LCH = LCH.Clearnet

NGX = Natural Gas Exchange
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 13

c. Data Dictionary for Section 20.4(c) Data Elements: Reporting Entities

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas”, contain complete example 

records using both FpML and FIXML.

(1) An identifier assigned by the Commission to the reporting entity;

(2) An identifier indicating that a principal or counterparty position is being reported;

(3) A 102S identifier assigned by the reporting entity to its counterparty;

(4) The name of the counterparty whose position is being reported;

(5) The reporting day;

(6) If cleared, the identifier for the cleared product assigned by the clearing organization;

(7) The commodity underlying the reportable positions; 

(8) The futures equivalent month;

(8)(i) Price reference month;

(9) A cleared or uncleared indicator;

(10) A clearing organization identifier;

(11) The commodity reference price; 

(11)(i) Position type indicator;

(12) An execution facility indicator;

(13) Long paired swap positions;

(14) Short paired swap positions;

(15) A swaption put or call side indicator;

(16) A swaption expiration date; 

(17) A swaption strike price;

(17)(i) Non-standard swaption indicator;

(18) Long non-delta-adjusted paired swaption positions;

(19) Short non-delta-adjusted paired swaption positions;

(20) Long delta-adjusted paired swaption positions (using economically reasonable and analytically supported deltas);

(21) Short delta-adjusted paired swaption positions (using economically reasonable and analytically supported deltas);

(22) Long paired swap or swaption notional value; and

(23) Short paired swap or swaption notional value.
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 14

Data Element CFTC Description, Purpose or Instruction FpML * FIXML*

(1) An identifier assigned by the Commission to 

the reporting entity

Reporting Firm ID assigned by CFTC for 

each reporting affiliate (legal entity) within an 

organization. Reporting entity should use 

previously assigned ID if it exists. 

exposureReport/onBehalfOf/partyReference

@href

(where partyReference@href = party@id)

exposureReport/party@id

exposureReport/party/partyId

exposureReport/party/partyName

PosRpt:Pty@ID=[Reporting ID]

PosRpt:Pty@Src=M

PosRpt:Pty@R=92

(2) An identifier indicating that a principal or 

counterparty position is being reported

An identifier assigned by the reporting entity 

to describe the ownership of the position 

(principal/agent or counterparty/customer). In 

the situation of a clearing member reporting 

paired swaps held by their customers (but to 

which the clearing member is not a principal), 

the clearing member may label the data 

records reflecting the positions of the 

customer as “Customer” and represent the 

positions opposite their customer’s positions 

as “Agent.” 

The Agent designation is intended to indicate 

that the party identified in that position report 

acted as an ‘Agent’ on behalf of a customer 

for that position in a paired swap. For 

example, when a clearing member acts as an 

agent for a customer to facilitate the purchase 

of a cleared swap position, the clearing 

member would report that they acted as an 

Agent for that position. Position records with 

an ‘Agent’ designation are distinct from 

position records with ‘Principal,” 

“Counterparty,” or “Customer” designations. 

exposureReport/exposure/category

Valid values:

“Principal”;

”Agent”; 

“Counterparty”;

”Customer”

PosRpt@PosCpcty=[0, 1, 2, 3]

Valid values:

0 = Principal

1 = Agent

2 = Customer

3 = Counterparty

(3) A 102S identifier assigned by the reporting 

entity to its counterparty

A unique identifier for each reporting entity 

or counterparty/customer as assigned by the 

reporting entity. Reporting entities will 

provide for both principal/agent and 

counterparty/customer. If the reporting entity 

currently identifies a counterparty on a Form 

102, the identifier used on the Form 102 may 

also be used for the 102S identifier, as long as 

the same legal entity is referenced. 

For Customer/Counterparty:

exposureReport/exposure/relatedParty/partyR

eference@href

(where partyReference@href = party@id)

exposureReport/exposure/relatedParty/role='C

ounterParty' 

exposureReport/party@id

exposureReport/party/partyId

exposureReport/party/partyName

For Principal/Agent: 

exposureReport/reportContent/partyReference

@href

(where partyReference@href = party@id)

exposureReport/party@id

PosRpt:Pty@ID=[102S Identifier]

PosRpt:Pty@Src=D

PosRpt:Pty@R=7

 
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 15

Data Element CFTC Description, Purpose or Instruction FpML * FIXML*

exposureReport/party/partyId

exposureReport/party/partyName

(4) The name of the counterparty whose position 

is being reported

Identifies the legal name of the counterparty 

whose position is reported as identified on the 

102S filing. Reporting entities will provide 

for both principal and counterparty or agent 

and customer. 

exposureReport/exposure/relatedParty/partyR

eference@href

(where partyReference@href = party@id) 

exposureReport/exposure/relatedParty/role='P

rincipal' or 'CounterParty' 

exposureReport/party@id

exposureReport/party/partyId

exposureReport/party/partyName

PosRpt:Pty:Sub@ID=[legal name]

PosRpt:Pty:Sub@Typ=5

valid values:

5 = Full legal name of firm

(5) The reporting day Identifies the day for which the records 

pertain (i.e. closing of books or valuations) or 

at the closing of the trading session. Includes 

the date, time and timezone offset.

exposureReport/asOfDate 

exposureReport/asOfTime

Valid formats:

YYYY-MM-DD

hh:mm:ss[+/-]hh:mm

PosRpt@BizDt=[YYYY-MM-DD]

PosRpt@TxnTm=[YYYY-MMDDThh:mm:ss[+/-]hh:mm]

Valid formats:

YYYY-MM-DD

YYYY-MM-DDThh:mm:ss[+/-]hh:mm

(6) If cleared, the identifier for the cleared 

product assigned by the clearing organization

A unique identifier for each cleared product 

that's assigned by the clearing organization. If 

the clearing code and commodity code are 

different, both must be provided. If uncleared, 

then this field will be null. 

exposureReport/exposure/

productId[@productIdScheme='clearing_org_

product_code']

PosRpt:Instrmt@ID=[Cleared Product ID]

PosRpt:Instrmt@Src=H

if commodity code is different:

PosRpt:PosUnd:Undly:AID@AltID=[Commo

dity code]

PosRpt:PosUnd:Undly:AID@AltIDSrc=M

(7) The commodity underlying the reportable 

positions

Identifies which of the 46 commodities listed 

in § 20.2 the record refers to, including the 

exchange and commodity code (e.g., CBT C). 

See Appendix A for the full list of commodity 

codes for each covered contract.

exposureReport/exposure/underlyingAsset/co

mmodity/commodityBase

PosRpt:PosUnd:Undly:AID@AltID=[Commo

dity code]

PosRpt:PosUnd:Undly:AID@AltIDSrc=[Q ]

valid values:

Q = CFTC Commodity Code

(8) The futures equivalent month Corresponds to the price exposure resulting 

from the swap. The futures equivalent 

positions generated from a swap would be the 

portfolio of futures contracts that would most 

closely provide the price exposure of that 

swap. The format provided should be year 

and month only.

exposureReport/exposure/futuresEquivalentM

onth

Valid formats:

YYYY-MM

PosRpt:PosUnd:Undly@MMY=[YYYYMM]

Valid formats:

YYYYMM

(8)(i) Price reference month The calendar month exposure resulting from 

1) a situation where a paired swap does not 

reference a DCM contract in §20.2 and the 

delivery of the instruments comprising the 

cash market index used for pricing does not 

coincide with any delivery window of a 

relevant DCM contract; or, 2) any exposure 

reported as part of a paired swap but which is 

exposureReport/exposure/priceReferenceMon

th

Valid formats:

YYYY-MM

PosRpt:PosUnd:Undly@PxRefMo=[YYYYM

M]

Valid formats:

YYYYMM
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 16

Data Element CFTC Description, Purpose or Instruction FpML * FIXML*

not in any of the commodities (or 

substantially the same commodities) 

underlying the DCM contracts listed in § 

20.2. The price reference month should, by 

definition, only be reported when there is not 

an applicable futures equivalent month for the 

position being reported. The format provided 

should be year and month only.

(9) A cleared or uncleared indicator Identifies if the product is cleared by a 

clearing organization. If the product is 

cleared, the Clearing Org ID and Clearing 

Product ID are required.

exposureReport/exposure/cleared

Valid values:

"false"=Not cleared;

"true"=Cleared

PosRpt@Clrd=[0, 1]

valid values:

0 = Not cleared

1 = Cleared

(10) A clearing organization identifier An identifier for each swaps clearing 

organization, assigned by the CFTC. Clearing 

member should provide the same Clearing 

Org ID used in § 20.3(b)(1). The list of 

identifiers may change/expand over time. If 

uncleared, then this field will be null.

exposureReport/exposure/relatedParty/partyR

eference@href

(where partyReference@href = party@id) 

exposureReport/exposure/relatedParty/role='C

learingOrganization' 

exposureReport/party@id

exposureReport/party/partyId

exposureReport/party/partyName

Valid values:

CME = CME Clearing House

ICUS = ICE Clear US

ICEU = ICE Clear Europe

LCH = LCH.Clearnet

NGX = Natural Gas Exchange

PosRpt:Pty@ID=[Clearing Org ID]

PosRpt:Pty@Src= M

PosRpt:Pty@R=21

Valid values:

CME = CME Clearing House

ICUS = ICE Clear US

ICEU = ICE Clear Europe

LCH = LCH.Clearnet

NGX = Natural Gas Exchange

(11) The commodity reference price CRP refers to the term as defined in SubAnnex A of the 2005 ISDA Commodity 

Definitions, or to any subsequent versions of 

that document.

exposureReport/exposure/underlyingAsset/co

mmodity/instrumentId[@instrumentIdScheme

='.../commodity-reference-price']

PosRpt:PosUnd:Undly@ID=[Commodity 

reference price code]

PosRpt:PosUnd:Undly:AID@AltIDSrc=[ R]

Valid values:

R = ISDA Commodity Reference Price

(11)(

i)

CRP position type indicator Additional information related to the pricing 

of the swaps position, specifically an indicator 

referring to the position type as defined below 

in the Guidebook. Position Type Indicators 

should be populated with one of the four 

options for each reportable swap and swaption 

position.

exposureReport/exposure/exposureType

Valid values:

“TwoComponentIntercommoditySpread”;

”IndexOrBasket”;

“TwoComponentLocationalBasis”;

“Other”

PosRpt@ConRefPosTyp=[0, 1, 2, 99]

Valid values:

0 = Two component intercommodity spread

1 = Index or basket

2 = Two component locational basis

99 = Other

(12) An execution facility indicator Indicates if the trade was conducted on an 

execution facility. For cleared swaps, 

compression, novation, and other similar 

exposureReport/exposure/relatedParty/partyR

eference@href

(where partyReference@href = party@id) 

PosRpt:Pty@ID=[MIC Code]

PosRpt:Pty@Src=G

PosRpt:Pty@R=22
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 17

Data Element CFTC Description, Purpose or Instruction FpML * FIXML*

actions may result in a position for which no 

execution facility can be assigned. In these 

cases, the indicator may be null. If the swap 

was transacted off of an execution facility, 

then the value may be null as well. For 

uncleared open swaps, the indicator must be 

the ISO MIC code. [See 

http://www.iso15022.org/MIC/homepageMIC

.htm] 

exposureReport/exposure/relatedParty/role='E

xecutionFacility' 

exposureReport/party@id

exposureReport/party/partyId

exposureReport/party/partyName

Valid values:

MIC code;

“ “(null)

(13) Long paired swap positions State number of gross long futures equivalent 

contracts. Format: decimal (4). If position is 

reported in units other than contracts include 

the units or currency. If position is reported in 

terms of a currency, include ISO currency 

code. Positions would not be reported as 

futures-equivalent positions only when the

underlying commodity for the position is 

reported as ‘Index’ or ‘Other’.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType

='LongSwapPosition'] 

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=GRS

PosRpt:Qty@Long=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency 

Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, 

g, Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, 

kW-d, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

valid values:

GRS = Gross paired swap position

(14) Short paired swap positions State number of gross short futures equivalent 

contracts. Format: decimal (4). If position is 

reported in units other than contracts include 

the units or currency. If position is reported in 

terms of currency, include currency (use ISO 

currency code). Positions would not be 

reported as futures-equivalent positions only 

when the underlying commodity for the 

position is reported as ‘Index’ or ‘Other’.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType

='ShortSwapPosition' 

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=GRS

PosRpt:Qty@Short=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency 

Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, 

g, Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, 

kW-d, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

Valid values:

GRS = Gross paired swap position

(15) A swaption put or call side indicator Put indicates a long or short put. Call 

indicates a long or short call.

exposureReport/exposure/optionType

Valid values:

“Put”;

“Call”;

“ “ (null)

PosRpt:Instrmt@PutCall=[0,1]

Valid values:

0 = Put 

1 = Call

(16) A swaption expiration date Indicates the year, month and day when the 

swaption expires.

exposureReport/exposure/expirationDate

Valid formats:

YYYY-MM-DD

PosRpt:Instrmt@MMY=[YYYYMMDD]

Valid formats:

YYYYMMDD

(17) A swaption strike price Strike price of swaption, using pricing exposureReport/exposure/quote/value PosRpt:Instrmt@StrkPx=[decimal number]
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 18

Data Element CFTC Description, Purpose or Instruction FpML * FIXML*

convention of contract. Includes currency 

(native) and unit and decimal. Use ISO 

currency code to report currency. Reported in 

dollars, not cents. Values can be negative. 

Format: decimal (4)

exposureReport/exposure/quote/measureType

='StrikePrice' 

exposureReport/exposure/quote/quoteUnit

exposureReport/exposure/quote/currency

PosRpt:Instrmt@StrkCcy=[ISO Currency 

Code]

PosRpt:Instrmt@StrkUOM=[Alw, Bbl, Bcf,

BDFT, Bu, CBM, Ccy, CDD, CER, CPD, 

CRT, cwt, day, dt, EnvAllwnc, EnvCrd, 

EnvOfst, FEU, g, Gal, GJ, GT, HDD, IPNT, 

kg, kL, kW-a, kW-d, kWh, kW-h, kW-M, 

kW-min , L, lbs, MMBtu, MW-a, MW-d, 

MWh, MW-h, MW-M, MW-min, oz_tr, 

PRINC, t, TEU, thm, tn]

(17)(

i)

Non-standard swaption indicator An indicator that identifies a non-standard 

swaption. See section II.g ‘Notes on NonStandard Options’ of this Guidebook for 

circumstances when a swaption would be 

considered non-standard.

exposureReport/exposure/productType

Valid values:

"Standard";

“NonStandard”;

“ “ (null)

PosRpt/Instrmt@SecTyp=[SWAPTION]

PosRpt/Instrmt@SubTyp=[S, N]

Valid values:

SWAPTION = Swaption as defined in § 20.1

Valid values:

S=Standard

N=NonStandard

(18) Long non-delta-adjusted paired swaption 

positions

State number of gross long non-delta adjusted 

futures equivalent contracts. Format: decimal 

(4).If position is reported in units other than 

contracts, include the units or currency. If 

position is reported in terms of a currency, 

include ISO currency code. Positions would 

not be reported as futures-equivalent positions

only when the underlying commodity for the 

position is reported as ‘Index’ or ‘Other’.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType

='NonDeltaAdjustedLongSwaptionPosition'

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=NDAS

PosRpt:Qty@Long=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency 

Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, 

g, Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, 

kW-d, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

Valid values:

NDAS = Gross non-delta-adjusted swaption 

position

(19) Short non-delta-adjusted paired swaption 

positions

State number of gross short non-delta adjusted 

futures equivalent contracts. Format: 

decimal (4). If position is reported in units 

other than contracts, include the units or 

currency. If position is reported in terms of a 

currency, include ISO currency code. 

Positions would not be reported as futuresequivalent positions only when the

underlying commodity for the position is 

reported as ‘Index’ or ‘Other’.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType

='NonDeltaAdjustedShortSwaptionPosition'

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=NDAS

PosRpt:Qty@Short=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency 

Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, 

g, Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, 

kW-d, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]
* This column is intended to provide only a partial example of acceptable FpML and FIXML. Section III of this Guidebook provides example Part 20 data records, and 

Appendices F through U, which are in a separate document titled “Guidebook for Part 20 Appendix Schemas,” contain complete FpML and FIXML schemas for these 

example data records. 

Page 19

Data Element CFTC Description, Purpose or Instruction FpML * FIXML*

Valid values:

NDAS = Gross non-delta-adjusted swaption 

position

(20) Long delta-adjusted paired swaption positions 

(using economically reasonable and 

analytically supported deltas)

State number of gross long delta adjusted 

futures equivalent contracts. See § 20.6(b) 

regarding retention of documentation of delta 

equivalent methodology. Format: decimal (4). 

If position is reported in units other than 

contracts, include the units or currency. If 

position is reported in terms of a currency, 

include ISO currency code. Positions would 

not be reported as futures-equivalent positions

only when the underlying commodity for the 

position is reported as ‘Index’ or ‘Other’.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType

='DeltaAdjustedLongSwaptionPosition'

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=DAS

PosRpt:Qty@Long=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency 

Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, 

g, Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, 

kW-d, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

Valid values:

DAS =Gross delta-adjusted paired swaption 

(21) Short delta-adjusted paired swaption positions 

(using economically reasonable and 

analytically supported deltas)

State number of gross short delta adjusted 

futures equivalent contracts. See § 20.6(b) 

regarding retention of documentation of delta 

equivalent methodology. Format: decimal 

(4). If position is reported in units other than 

contracts, include the units or currency. If 

position is reported in terms of a currency, 

include ISO currency code. Positions would 

not be reported as futures-equivalent positions

only when the underlying commodity for the 

position is reported as ‘Index’ or ‘Other’.

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType

='DeltaAdjustedShortSwaptionPosition'

exposureReport/exposure/quote/quoteUnits 

exposureReport/exposure/quote/currency

PosRpt:Qty@Typ=DAS

PosRpt:Qty@Short=[decimal number]

PosRpt:Qty@UOMCcy=[ISO Currency 

Code]

PosRpt:Qty@UOM=[Alw, Bbl, Bcf, BDFT, 

Bu, CBM, Ccy, CDD, CER, CPD, CRT, cwt, 

day, dt, EnvAllwnc, EnvCrd, EnvOfst, FEU, 

g, Gal, GJ, GT, HDD, IPNT, kg, kL, kW-a, 

kW-d, kWh, kW-h, kW-M, kW-min , L, lbs, 

MMBtu, MW-a, MW-d, MWh, MW-h, MWM, MW-min, oz_tr, PRINC, t, TEU, thm, tn]

Valid values:

DAS = Gross delta-adjusted paired swaption 

position

(22) Long paired swap or swaption notional value Indicates the notional value of the paired 

swap or swaption long futures equivalent 

position. The product of the value of the 

number of futures equivalent contracts and the 

price used in swap agreement. Use ISO 

currency code; report in USD. Format: 

decimal (2)

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType

='LongNotionalPosition'

PosRpt:Amt@Typ=LSNV

PosRpt:Amt@Amt=[decimal number]

Valid values:

LSNV = Long paired swap or swaption 

notional value

(23) Short paired swap or swaption notional value Indicates the notional value of the paired 

swap or swaption short futures equivalent 

position. The product of the value of the 

number of futures equivalent contracts and the 

price used in swap agreement. Use ISO 

currency code; report in USD. Format: 

decimal (2)

exposureReport/exposure/quote/value 

exposureReport/exposure/quote/measureType

='ShortNotionalPosition'

PosRpt:Amt@Typ=SSNV

PosRpt:Amt@Amt=[decimal number]

Valid values:

SSNV = Short paired swap or swaption 

notional value
Page 20

d. Notes on Commodity Reference Prices

The Commodity Reference Price (“CRP”) data element requested by the Commission for § 20.3 and § 20.4 reports corresponds to that term as 

defined in the Sub-Annex A of the 2005 ISDA Commodity Definitions, or to any subsequent versions of that document. If the CRP resulting 

from a reportable position of a paired swap is not defined in Sub-Annex A of the 2005 ISDA Commodity Definitions, or any subsequent 

version of the document, reporting entities shall use the CRP that the clearing organization has created for that price exposure if the paired 

swap is a cleared swap. If the paired swap is uncleared, or if the clearing organization offers no substitute CRP value in the instance where the 

applicable price series is not defined in the ISDA Commodity Definitions, reporting entities shall then provide in the CRP data element field a 

description of the price source and heading that they are using to price the swap.

If new CRPs are added to Sub-Annex A of the 2005 ISDA Commodity Definitions, or any subsequent version of that document, it is the 

responsibility of reporting entities to adopt new CRPs as appropriate. Swap positions previously reported using a customized description 

should thereafter be reported using the relevant newly published ISDA CRP definition.

For the purpose of reporting under Part 20, the CRP includes a CFTC defined Position Type Indicator for each data record as follows –

The CRP Position Type Indicator field will have the following mutually-exclusive values:

• “TwoComponentIntercommoditySpread” for swaps:

o Composed of exactly 2 different commodity components;

o 1 long commodity component; and

o 1 short commodity component.

• “IndexOrBasket” for swaps:

o Composed of 2 long positions in different commodities;

o Composed of 2 short positions in different commodities; or

o Composed of positions in more than 2 different commodities.

• “TwoComponentLocationalBasis” for swaps:

o Composed of exactly 2 positions in the same (or substantially the same) commodity;

o The 2 positions call for delivery at different locations; and

o The pricing of the transaction is the difference in the locational prices.

• “Other” for swaps that are none of the above.

Along with other factors, the CRP Position Type Indicator makes use of distinctions between commodities to define CRP Position Types. For 
Page 21

example, the “TwoComponentIntercommoditySpread” type requires that the two components pertain to different commodities. If these 

commodities are closely related but determined to be “different”, then the “TwoComponentIntercommoditySpread” value may be applied to 

that position, should the other requirements of that definition be satisfied as well. Alternatively, if those same two closely-related 

commodities are determined to be the “same” commodity, then the position could not be classified as a 

“TwoComponentIntercommoditySpread” position. Instead, the position may be characterized as “TwoComponentLocationalBasis” or, more 

likely, as an “Other” CRP Position Type.

The “same” commodity (in reference to some other commodity position) is defined to be any grade or type that is deliverable against the 

DCM covered contracts listed in § 20.2. For example, any crude oil blend that is deliverable against the ‘NYMEX Crude Oil, Light Sweet’

contract is considered to be the same commodity as the primary deliverable grade. Other crude oil blends that do not meet the deliverability 

standards of the relevant § 20.2 contract are as of this time not considered to be in the “same” commodity. Reporting entities under Part 20 

should label their paired swap positions using the CRP Position Type Indicator in accordance with the above definition of the “same” 

commodity. Persons may seek guidance from Commission staff as to what constitutes “substantially the same” commodity on a case-by-case 

basis.

A position is determined to be in a “different” commodity if it does not meet the definition of being in the “same, or “substantially the same”

commodity, relative to the other position(s) in question. The definitions of the “same” and “substantially the same” commodity have

important implications for the application of the CRP Position Type Indicator, and reporting entities are advised to carefully consided the 

details of the transactions that result in paired swap positions so that the correct CRP Position Type Indicator is used. As an example, a longonly basket-style transaction that involves many different crude oil prices may not yeild a position that qualifies as an “IndexOrBasket” CRP 

Position Type if those crude grades are all the “same”, as defined above. Given the existing definitions, these positions would be classified as 

“Other”.

e. Notes on Reporting by Data Records Associated with CFTC Defined Basis Swaps, Inter-Commodity Spread Swaps and 

Commodity Index Swaps

In order to clearly represent the position records resulting from paired swaps that are one of the above-mentioned Position Types, reporting 

entities shall "decompose" the exposures resulting from any such Position Types in the following manner. A

“TwoComponentLocationalBasis” transaction should result in a separate data record for each commodity exposure. The one exposure that 

renders the swap a paired swap shall use the Commodity and CRP data elements that are applicable. The other exposure from the transaction, 

while standing on its own may not qualify as a paired swap, shall nevertheless be reported in a separate data record because it is based on the 

same commodity (or substantially the same commodity). For the other exposure resulting from a basis transaction, which is defined as a 

transaction between two separate delivery locations for the same commodity, the Commodity data element shall be the same as the exposure 

rendering the transaction a paired swap. The CRP, however, may be distinct from the exposure that rendered the transaction a paired swap, 

and reporting entities shall submit information on the CRP as accurately as possible. For details, please see the above note on CRPs. Both 
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data records should indicate “TwoComponentLocationalBasis” for a CFTC defined locational basis swap in the CRP Position Type Indicator 

field.

The decomposition of exposures resulting from paired swap transactions is pertinent in the case of commodity index swaps meeting the 

definition of “IndexOrBasket” for the CRP Position Type Indicator. For diversified commodity index swaps (see §§ 20.2 and 20.11), data 

records may indicate the Commodity as "Diversified Commodity Index" and the CRP as the value that corresponds to that entire published 

index (“Index ABC”). In these cases, the Commission will take the necessary steps to "decompose" the exposures resulting from such 

publically-known indices into the underlying exposures for surveillance functions. 

Alternatively, reporting entities may report the "decomposed" exposures from any diversified commodity index, and should report the 

"decomposed" exposures from any commodity index not meeting the criteria for diversified commodity indexes. In these instances, if a 

component of the index results in a futures equivalent position in any of the contracts listed in § 20.2, then that value should be used for the 

Commodity data element. If one or many of the positions resulting from the commodity index cannot be described by the contracts listed in §

20.2, then the Commodity data element may have the value of “Other”. It is optional but recommended to report any exposures of 

Commodity type “Other”. Regardless of whether only paired swap positions or all positions resulting from a decomposed IndexOrBasket 

position are reported, the CRP should be provided in all cases for each exposure or position resulting from that commodity index, even if the 

Commodity data element for a particular data record is “Other”. Furthermore, all data records should indicate “IndexOrBasket” for a CFTC 

defined commodity index swap in the CRP Position Type Indicator field. 

Similarly, counterparties to CFTC defined inter-commodity spread that qualify as paired swaps shall report all exposures resulting from that 

swap if both “legs” would individually qualify as paired swaps. Separate data records shall be submitted for the exposure resulting from each 

“leg”. The Commodity and CRP variables shall be reported in a manner similar to the treatment of CFTC defined commodity index swaps.

Again, it is optional to report non-paired swap positions that are associated with the paried swap position that meets the definition of 

“TwoComponentIntercommoditySpread” The CRP Position Type Indicator field for all positions from such swaps should be marked as 

“TwoComponentIntercommoditySpread.”

Please see data records 71-78, 79-102, 103-106,107-110, and 111-120 which result from swaps L, M, N, O, and P, respectively, for examples 

of the "decomposed" exposures presented in data records.

f. Notes on CFTC Commodity Index and Diversified Commodity Indices Definitions

As noted above, a commodity index swap has the following properties:

o Composed of 2 long positions in different commodities;
Page 23

o Composed of 2 short positions in different commodities; or

o Composed of positions in more than 2 different commodities.

A commodity index swap is a swap that is not a two component locational basis or spread contract which is settled on the price of three or 

more commodities. A commodity index swap is also a swap that is settled on the price of two commodities as long as that swap does not 

settle upon the difference in the prices of those two commodities. Whether two or more commodities are determined to be the “different” or 

not is discussed above in section d.

For example, a swap that gives long-only exposure to two or more commodities is a commodity index swap for the purposes of reporting 

under Part 20. A swap that gives long exposure to one commodity and short exposure to two different commodities would also be reported as 

a commodity index swap. 

A swap that provides exposure to only two commodities, and provides long exposure to one commodity and short exposure to the other 

commodity, is not a CFTC-defined commodity index swap. This swap would be an inter-commodity spread swap.

Section 20.11 states that “[f]or the purpose of reporting in futures equivalents, paired swaps and swaptions using commodity reference 

prices that are commonly known diversified indices with publicly available weightings may be reported as if such indices underlie a single 

futures contract with monthly expirations for each calendar month and year.”

Reporting entities may choose to report Diversified Commodity Indices as if the indices are § 20.2 covered contracts rather than decomposing 

the indices into futures-equivalent components by commodity. Reporting entities that choose to report in this way would enter into the 

Commodity Reference Price field the Bloomberg ticker symbol of the Diversified Commodity Index (“Index ABC”) and a ‘commodity 

underlying the reportable position’ of “Diversified Commodity Index.” This would identify that the position being reported is in a Diversified 

Commodity Index called “Index ABC.” 

If the position in the Diversified Commodity Index is reported in this way, the long or short position should be reported in the ‘native’ units of 

the index. However, if the reporting entity chooses to report the position in decomposed form by commodity, the reporting entity would need 

to follow the futures equivalence guidelines described herein. 

For swaps on Diversified Commodity Indices that reporting entities choose to report in terms of the index, the Commodity Reference Price 

for that position report should be the Bloomberg ticker symbol for that index. For example, positions in swaps on the Standard and Poor’s 

GSCI should be reported with a Commodity Reference Price of SPGSCI. Swaps on the Dow Jones-UBS Energy Total Return Sub-Index 

should have a Commodity Reference Price of DJUBENTR.
Page 24

g. Notes on Non-Standard Options

Representing the features of many non-standard swaptions may be difficult with the limited data elements required by § 20.3 and § 20.4

reports. Examples of such non-standard swaptions include swaptions with multiple strike prices, or swaptions with notional sizes in units 

different from those of the reportable positions resulting from that swaption. The strike prices and non-delta-adjusted positions resulting from 

such swaptions may not be interpreted easily.

i. Use of the Non-Standard Swaption Indicator

To accommodate reporting entities, in lieu of reporting certain information in the strike price and non-delta-adjusted data elements that would 

not at this time provide clearly and fully the details of that swaption from the individual data record, reporting entities may use an indicator to 

convey that a particular position results from a non-standard swaption.

The use of the non-standard swaption indicator (incorporated as data element 20.3(b)(12)(i) and § 20.4(c)(17)(i)) does not remove the 

obligation of the reporting entity to accurately report delta-adjusted positions, along with all other applicable data elements required under §§ 

20.3 and 20.4, and may result in additional surveillance activities to monitor and better understand such non-standard swaption positions 

through the exercise of special call authority under § 20.6.

Notwithstanding the above guidance, each reporting entity must, to the best of their ability, attempt to complete all of the swaptions-related 

data elements in §§ 20.3 and 20.4. Reporting entities must determine the reportability of the strike price and non-delta adjusted position data 

elements on a swaption-by-swaption basis. No reporting entity is granted ‘blanket’ relief from reporting these fields.

ii. Reporting Positions from Swaption Transactions with a Non-Standard Strike Price

The Swaption Strike Price data element is generally comprised of three XML components which correspond to the value of the strike price, 

the units for the strike price, and the currency for the strike price. Representing the Swaption Strike Price data element through these XML 

components may be performed in different ways for swaption positions.

For a simple swaption where a single underlying instrument is used for the strike, the strike price may be expressed naturally. However, in the 

case where a position results from a differencing transaction, the swaption strike price value may represent the difference in price of two or 

more underlying instruments. In this case, the Non-Standard Swaption Indicator should be used, and the strike price value should be as 

specified in the contract. When swaption positions result from a Diversified Commodity Index, the swaption strike price value should be the 

value as specified in the contract and the strike units should be presented as the Bloomberg ticker for the Diversified Commodity Index. This 

guidance is applicable whether or not the exposures from the Diversified Index are decomposed. If a swaption on a Diversified Commodity 

Index involves a strike price that is different than the Index itself, please follow the guidance below that pertains to swaptions on customized 

indices. 
Page 25

Finally, when reporting a swaption position that results from a customized index (i.e. one that is not publically-known) and when the strike 

price cannot be expressed as a value of a single underlying instrument, the strike price value should be submitted as is specified in the 

contract. However, the value for the units associated with the strike price should be a key that uniquely identifies the components and 

construction of the strike price. This key should be alpha-numeric (do not use reserved characters), less than 243 characters, and preceded by 

“Custom_Strike_”. Should the Commission contact a reporting entity and request information regarding the strike price that is associated with 

a particular position, this custom strike key will be referenced. For this reason, firms submitting futures equivalent swaption positions from 

customized indices should keep information regarding the composition of the strike price of such transactions readily available.

The guidance on this issue is summarized in the following table:
Page 26

Reporting Positions from Swaptions with Non-Standard Strike Prices

Swaption Situation Solution

Use NonStandard 

Swaption 

Indicator?

*

Strike Price Data Element Examples:

Strike 

Value

Strike 

Units

Strike 

Currency

1 Simple Swaption on a non-index, nondifferencing underlying instruments. Report the strike price naturally. No 10.0000 MMBTU USD

2

Swaption on spread/basis or any type of 

differencing contract (e.g. the strike price 

may be for the difference in value of two or 

more underlying instruments).

Report the strike price naturally, even if the strike is for the 

difference in values between underlying instruments, as 

long as the underlying instruments are measured in the 

same units. If not, follow the guidance for Swaption 

Situation 5 in reporting the strike units.

Yes 0.2500 MMBTU USD

3

Swaption on publically-known index (i.e. 

priced off an index that can be described by 

a CRP; known weightings) where exposures 

are reported without decomposition of the 

index.

Report the “strike value” in terms of the index. Use the 

Bloomberg index ticker as the “strike units”. Strike 

currency may be included if that particular index is 

published with an associated currency, but is not necessary.

Yes 105.1255 DJUBSE

NTR USD or Null

4

Swaption on publically-known index (i.e. 

priced off an index that can be described by 

a CRP; known weightings) where exposures 

are reported after decomposition of the 

index.

Report the “strike value” in terms of the index. Use the 

Bloomberg index ticker as the “strike units”. Strike 

currency may be included if that particular index is 

published with an associated currency, but is not necessary.

Yes 2.2500 TOPAGI

NDX USD or Null

5

Swaption on a customized index (i.e. not 

publically known) when exposures from the 

index are decomposed and reported.

Provide a key that uniquely identifies this strike price. The 

Strike Units XML data element should begin with 

“Custom_Strike_” and the value for the key should be 

submitted after the second underscore. The values for the 

key itself should be alpha-numeric and less than 243 

characters; do not use any conserved characters. Strike 

currency may be included if that particular index is 

published with an associated currency, but is not necessary.

Yes 33.0000

Custom_S

trike_AB

CD22

USD or Null

*Because of this particular strike price scenario of the swaption. Other features of the swaption may further justify the use of the Non-Standard Swaption Indicator.
Page 27

h. Notes on the Execution Facility Indicator

Data element (12) in § 20.4 reports is “an execution facility indicator.” Industry feedback indicates that certain positions may not be 

amenable to reporting by execution facility. For example, a 50 long position was obtained through Execution Facility A and the two 35 short

position were obtained through Execution Facility B and C, difficulties arise in assigning an Execution Facility to the net short position of 20.

In such cases, the Execution Facility field should be ‘null.’ The value for the Execution Facility Indicator will also be ‘null’ in the case where 

the transaction was not conducted on an execution facility. The Execution Facility should still be reported for cleared and uncleared swaps 

positions where it is appropriate to do so and where the information can be reported accurately. See http://www.iso15022.org/MIC/homepageMIC.htm.

i. Notes on the 102S Filing

The 102S identifier is a unique identifier for each reporting entity or counterparty/customer as assigned by the reporting entity. Reporting 

entities will provide for both principal/agent and counterparty/customer. If the reporting entity currently identifies a counterparty on a Form 

102, the identifier used on the Form 102 may also be used for the 102S identifier, as long as the same legal entity is referenced.

§ 20.5(a)(1) specifies that, “When a counterparty consolidated account first becomes reportable, the reporting entity shall submit a 102S 

filing, which shall consist of the name, address, and contact information of the counterparty and a brief description of the nature of such 

person's paired swaps and swaptions market activity.
Page 28

102S Data Dictionary

Data Element CFTC Description, Purpose or Instruction Valid Values File Field Name

(1) An identifier assigned by the 

Commission to the reporting 

entity

Reporting Firm ID assigned by CFTC for each 

reporting affiliate (legal entity) within an 

organization. Same as § 20.4(c)(1). ClearingMemberId

(2) 102S Identifier A unique identifier for each reporting entity or 

counterparty/customer as assigned by the 

reporting entity. If the reporting entity 

currently identifies a counterparty on a Form 

102, the identifier used on the Form 102 may 

also be used for the 102S identifier, as long as 

the same legal entity is referenced. 102SId

(3) Name Identifies the legal name of the 

counterparty/customer with a reportable 

position in a consolidated account CounterpartyName

(4) Address Address for the entity referenced in the 102S 

filing Address

(5) Contact Name Contact name for a representative/ employee 

of the entity referenced in the 102S filing

Contact

Name

(6) Contact Job Title Job title for the representative/ employee ContactJobTitle

(7) Contact Phone Number Phone number for the representative/ 

employee

##########

ContactPhone

(8) Contact email address Email address for the representative/ 

employee

example@email.com

ContactEmail

(9) Nature of paired swaps and 

swaptions market activity

Brief description of the nature of such 

person’s paired swaps and swaptions market 

activity NatureOfSwapsActivity

(10) Reporting Date Date on which 102S filing is submitted YYYY-MM-DD ReportingDate
Page 29

§ 20.5(a)(2) specifies that each reporting entity shall submit only one 102S filing for each counterparty, even if that counterparty has positions 

in multiple swaps or swaptions. Additionally, reporting entities shall update the 102S filing if the information is no longer accurate.

§ 20.5(a)(3) specifies that each reporting entity shall submit a 102S filing within three days following the business day upon which the 

position in the consolidated account identified by the 102S identifier first becomes reportable. Also, a 102S filing must be submitted upon 

special call by the Commission.

102S Submission Procedure

The 102S filing submission may be completed by ftp’ing to the CFTC’s secure FTP site or by emailing the Excel file with the required 

information to the CFTC’s 102S filing mailbox at 102SFiling@cftc.gov. The naming convention for this file should be 

102S_[IDENT]_[YYYYMMDD].xls or .xlsx. The file layout can be found in Appendix D. Reporting entities who submit 102S filing 

should attempt to minimize the number of submission emails sent each day by including multiple 102S filings in a single Excel file.*

j. Paired Swaps: Guidelines for Linkage to § 20.2 Contracts

To determine whether a particular swap or swaption is “paired” as defined in § 20.1, reporting parties should reference the CRP fields for 

swaps and answer the following questions.

Does the swap reference a CRP that is a § 20.2 contract?

 If yes, the swap is a paired swap subject to Part 20.

Does the swap reference a CRP that is not a § 20.2 contract, but that nonetheless is the price of the same commodity as a § 20.2 contract for 

delivery at the same location? 

 If yes, the swap is a paired swap subject to Part 20.

 * On November 18, 2013, the Commission adopted new rules that require, among other things, the electronic submission of a new Form 102S (the “New Form 102S”). 

See Commission, Ownership and Control Reports, Forms 102/102S, 40/40S, and 71; Final Rule, 78 FR 69178 (Nov. 18, 2013). On July 23, 2014, the Division issued noaction relief that provided additional time, until February 11, 2015, for reporting parties to comply with the requirement to submit the New Form 102S, and on February 

10, 2015 the Division extended this no-action relief until September 30, 2015.
Page 30

Does the swap reference a CRP that in turn explicitly references in any way, whether through a pricing formula or survey, the price of the 

same commodity as a § 20.2 contract for delivery at the same location? 

 If yes, the swap is a paired swap subject to Part 20.

Examples:

• Properties: Some crude oil swaps specify a CRP called “Wall Street Journal Daily Published Price of US Crude Oil,” and the 

methodology for calculating that published price of crude oil is to take an average of the daily price of the front month NYMEX CL 

contract and a published price of a different crude oil type.

Conclusion: Any swaps with such a CRP would meet the price linkage requirements and would be paired swaps.

• Properties: Some swaps specify a CRP which is a published survey assessment. The survey for the assessments explicitly collects volume 

weighted cash market transactions in the same commodity and at the same delivery location as that of a § 20.2 contract.

Conclusion: Any swaps with such a CRP would meet the price linkage requirements and would be a paired swap.

• Properties: Some swaps specify a CRP that is a published survey assessment (other than as described immediately above) that includes 

volume weighted cash market transactions. In this case, the survey does not explicitly identify that it may collect transactions in the same 

commodity at the same delivery location as that of a § 20.2 contract. 

Conclusion: Because the survey may not include transactions in the same commodity in the same delivery location as a § 20.2 contract,

swaps with such a CRP would not meet the price linkage requirements and thus would not be paired swaps.

k. Notes on Notional Value 

Notional value must always be reported in US dollars (USD). To calculate the long and/or short notional value data element requested in 

§20.4 reports, the long and/or short futures equivalent or price reference month position should be multiplied by the relevant price. The 

relevant price is the value of the commodity reference price associated with the position displayed in each data record. For swaptions, the 

delta-adjusted long and/or short position should be multiplied by the relevant settlement price for that particular exposure of the swaption. 

Typically the relevant price will be the settlement price of the underlying on that report date. The discussion of the examples in the 

Guidebook reflects this methodology. 

l. Futures Equivalency Guidelines 

The purpose of the futures equivalency guidelines is to supplement the Appendices to Part 20 as well as provide more precise instruction on 
Page 31

specific types of swaps not adequately addressed in the Appendices.

Generally, the futures equivalent month of a swap, or for some portion of a swap’s duration, should correspond to the price exposure resulting 

from the swap. Stated another way, the futures equivalent positions generated from a swap would be the portfolio of futures contracts that 

would most closely provide the price exposure of that swap. Report all futures equivalent positions to four decimals (rounded).

The futures equivalent contracts resulting from this treatment of swaps may differ in some ways from the risk management practices that a 

firm may use in that the futures equivalents may not be the same as the futures contracts and contract expiration months that a firm could 

actually use to offset the risk of a particular swap. For example, if a swap generated price exposure to the monthly settlement of a futures 

contract for twelve consecutive futures contract expirations, this price exposure could be offset by “stacking and rolling” a futures market 

position forward from month to month as liquidity migrates to the nearby futures expiration months. While this may be an acceptable risk 

management practice, representing the futures equivalent position resulting from the swap as if, for the first month, all twelve months of price 

exposure was obtained from the nearby futures contract, would be incorrect and not consistent with the intent to best represent the price 

exposure generated by a swap in terms of futures equivalent months. 

i. Swaps Linked to a DCM Contract

Paired swaps directly or indirectly priced off of DCM contracts listed in § 20.2 are fairly straightforward to convert to futures equivalents. 

The terms of the swap will specify the Specified Price and Delivery Date(s) of each Pricing Date during the swap’s duration. The notional 

quantity of the swap is then apportioned to the relevant futures equivalent months as per the specifications of the swap transaction, and then 

divided by the relevant § 20.2 futures contract size to calculate the number of futures equivalent contracts for each applicable futures month.

In the event where a swap has a long duration and is priced off a DCM contract that does not list contract expirations as far into the future, the 

swap shall be converted as necessary into futures equivalent months that are reasonably expected to be listed in the future, as per the guidance 

of the relevant futures contract specifications. For example, the monthly expirations of the NYMEX “CL” crude oil contract are listed nine 

years forward, although years six through nine only provide a June and December contract. A swap with a ten-year duration that prices off of 

each consecutive expiration of the NYMEX “CL” crude oil contract could be reported, on the first day of its inclusion in a reportable position, 

as if it resulted in positions in futures equivalent months that have not yet been listed for trading by an exchange. In this case, the 

counterparties to the swap, in their selection of pricing mechanism, are assuming that the far-out contract months will eventually be listed, so 

it is appropriate to report the relevant parts of the swap exposure in terms of those not-yet-listed futures equivalent months.

ii. Swaps Not Linked to a DCM Contract

Paired swaps not priced off of a DCM contract, but instead priced to a commodity with the same delivery location(s) as the DCM contracts 

listed in § 20.2, are less straightforward to convert to futures equivalent positions. The cash market surveys used in these cases usually consist 

of spot or short-term forward prices. 
Page 32

If the swap pricing refers to a spot or short-term forward price series, then it is appropriate to convert the notional quantity of the swap into 

futures equivalent positions of the futures contract that will deliver at the same time as the cash market transactions in that price series. 

Although less common, if the swap was priced using an index of long-term forward contracts, then the futures equivalent month(s) of the 

swap should reflect the delivery dates of the forward contract index, since the long-term forward contracts are likely to be priced similarly to 

futures contracts that are concurrently trading with similar delivery dates. 

For example, a swap priced using a value of a gasoline spot market price on September 15, 2011 would be converted to September futures 

equivalent position, even though the September contract settles on August 31, 2011. This swap would result in futures equivalent positions in 

the September contract even though it will not be possible to actually hold open futures positions in this contract beyond the settlement date. 

The delivery window of the September gasoline (RB) contract is 9/09/2011-9/29/2011, therefore the cash market transaction on 9/15/2011 

will occur during this timeframe. 

iii. Price Reference Month

The Price Reference Month data field shall be used in lieu of the futures equivalent month data field in the following situations:

1) In the event that a swap is priced off the same commodity underlying the DCM contracts listed in § 20.2 but the delivery of the 

referenced cash market transaction(s) occurs during a calendar month when no futures contract is slated to be potentially deliverable, 

the Price Reference Month for the swap, or for some duration of the swap, shall be the calendar month of the referenced cash market 

delivery date(s). Because the swap position does not have a true futures equivalent in cases like this, the exposure resulting from the 

swap shall be termed a Price Reference Month, and distinguished from Futures Equivalent months in Part 20 reports.

2) Any exposure reported as part of a paired swap but which is not in any of the commodities underlying the DCM contracts listed in 

§20.2. The price reference month should, by definition, only be reported when there is not an applicable futures equivalent month for 

the position being reported. Practically, Price Reference Month will be used in this context when the data record Commodity value 

reflects “Other” or “Diversified Commodity Index”.

3) As a corollary, for swaps linked to futures contracts that have 12 monthly expirations each calendar year and that are reported in 

futures equivalent positions (rather than as part of a Diversified Commodity Index), the Futures Equivalent Month field will always be 

used to identify the month of the exposure.

iv. Daily and Weekly Swaps

Daily and weekly swaps can be converted into futures equivalents in the manner described above. If the daily or weekly swap references a 

settlement from a non-DCM reference price, then follow the general guidance provided above for reporting futures equivalent months for 

swaps not priced off a DCM contract. 
Page 33

v. Average Price Swaps

Swaps with average pricing result in a decreasing futures equivalent position over time as the price values of each calculation period become 

certain. For example, a swap where the floating price is the simple average of the next thirty days of daily settlements of some DCM contract, 

would have a futures equivalent position on the day before the first pricing day equal to the notional size of the swap divided by the size of 

the DCM contract. On the next day, after the first pricing day has occurred (or 1/30 of the inputs to the floating price are now certain) the 

futures equivalent position would be 29/30ths of the notional size of the swap divided by the size of the DCM contract.

Example 1 of Appendix A to Part 20 displays the calculation of futures equivalent positions from a similar swap with average pricing. 

Average price swaps are also represented in the example data records submitted by swap dealers and clearing members in this guidebook.

vi. Variance and Volatility Swaps

As of this time, this Guidebook does not include guidance as to how to report positions resulting from variance and volatility swaps, and 

similar transactions as discussed further below, on a regular basis under Part 20. Positions reported under Part 20 are represented in long or 

short units equivalent to one of the covered contracts in § 20.2, and in certain cases, to some “Other” commodity or to an “Index”. As such, 

each swap position report contains positions equivalent to a long and/or short position in one of those contracts.

Volatility is defined as the difference in prices across time. Variance is a measure of the distribution of a sample of prices. As such, these are 

fundamentally different measures than the long and short directional price exposure that is measured using futures equivalent units. Therefore, 

a variance or volatility swap may meet the definition of a paired swap, but it may be difficult or misleading to express in terms of futures 

equivalent units using the data elements prescribed for Part 20 reports.

However, reporting entities are not granted ‘blanket’ relief from reporting positions from transactions termed as either “variance swaps”, 

“volatility swaps”, or other similar terms; rather, if reporting entities determine on a case-by-case basis that the positions resulting from such 

transactions cannot be expressed as a futures equivalent position, then they are not required to make regular reports on these positions under 

Part 20.

In addition, please note that regulation § 20.6 still remains in effect towards variance and volatility swaps that are paired swaps. Such swap 

positions and transactions may also be subject to a special call made by the Commission under § 18.05.

m. Notes on the Manner of Reporting

The following guidance pertains to the timely reporting of data records under Part 20. In order to standardize and simplify the reporting 

requirements for reports submitted under Part 20, the following reporting schedule for Part 20 reports is offered to reporting entities and 

clearing organizations as per the authority under § 20.7 to establish the manner of reporting.
Page 34

Section 20.7(b) directs clearing organizations to submit § 20.3(b) and § 20.3(c) reports no later than 9:00 a.m. eastern standard time on the 

next business day following a reporting day. Similarly, § 20.7(c) directs reporting entities to submit § 20.4(c) reports no later than 12:00 p.m. 

eastern standard time on the second business day following the reporting day.

The definition of business day in § 1.3 of the Commission’s regulations includes all days except Sundays and holidays. For the purposes of 

complying with Part 20, reporting entities may elect to not consider Saturdays to be a business day, as Saturday is not commonly known as 

such. Instead, clearing organizations and reporting entities may submit Part 20 data records under the schedule displayed in the following 

tables. In the tables, the submission day is the day of the week that the relevant report for the associated reporting day is expected by the 

Commission. The time during the day that reports are expected is unchanged from § 20.7(b) and § 20.7(c). 

The reporting schedule displayed in the tables below does not take into account any holidays. To the extent that a U.S. Federal government 

holiday falls on either the submission day, and additionally in the case of § 20.4(c) reports, the day prior to the submission day, it is 

permissible for the submission of the applicable Part 20 data record to occur on the business day immediately after the usual submission day. 

Please note that any submission made under Part 20 can be made prior to the relevant submission day shown below. Early submission is 

beneficial in that it may allow the Commission to review your submission earlier and provide more timely feedback regarding the 

acceptability of the file structure and data contents.

Reporting Schedule for § 20.3(b) and § 20.3(c) Reports

Reporting Day Monday Tuesday Wednesday Thursday Friday Saturday Sunday

Submission Day Tuesday Wednesday Thursday Friday Monday Monday Monday

Reporting Schedule for § 20.4(c) Reports

Reporting Day Monday Tuesday Wednesday Thursday Friday Saturday Sunday

Submission Day Wednesday Thursday Friday Monday Tuesday Tuesday Tuesday

III. Data Record Layout Examples

The following examples display hypothetical data records that are generated from hypothetical swaps under a number of different scenarios. 

Each set of data records is designed to display a different aspect of the swaps large trader reporting methodology. 

Data records 1-3 (from swaps A, B, and C) show a straightforward application of the futures equivalent conversion and reporting 

methodology, specifically the manner by which multiple transactions may result in positions that are combined into the same data records. 

Conversely, data records 4-9 (from swap D) detail the manner by which a single swap transaction may result in many futures equivalent 

positions. 
Page 35

Data records 10-11 (swap E) show the positions generated when a swap is a paired swap but not directly linked to a §20.2 contract. Data 

records 12-17 (swaps F, G, and H) display the manner by which a reporting entity may come to show a long and short position in the same 

data record. Data records 18-19 (swap I) show the data records generated by an un-exercised swaption. The discussion for these data records 

details the particular reporting conventions to follow when reporting swaption positions.

Data records 20-25 (from swap J) show the position reports generated by a non-clearing entity when a swap is brought to clearing. 

Furthermore, these examples detail the reporting of swaps which include average pricing mechanisms. Data records 26-27 (from swap K) 

show the position records generated by a daily swap. The associated discussion details issues particular to the reporting of daily swaps. Data 

records 28-52 show the positions generated by the same reporting entity featured in data records 1-27 but for a different reporting day. The 

discussion highlights the instances where the data records reported differ or remain constant across time. 

Data records 53-70 display the data records generated by a clearing member when it brings a swap to clearing on behalf of its customers

(swap J, as referenced in data records 20-25). Data records 71-78 (from swap L) display the positions generated by a swap involving gold and 

Eurodollars; as such, these data records display the use of the Price Reference Month data element. Data records 79-102 (swap M) display the 

data records generated by swaption strip that entails a number of different swaption expiration dates. Data records 103-106 show the position 

records resulting from all of the components of a commodity index swap (swap N), while data records 107-110 show the position records 

generated by each exposure or “leg” of a locational basis swap (swap O).

Finally, data records 111-112 (swap P) display the data records generated by a swap dealer who enters into a Diversified Commodity Index 

swap and chooses to report the paired swaps in terms of the index, and not decompose the exposure of that index. Data records 113-120 again 

display exposures from swap P, but now they are decomposed are reported in terms of the underlying Futures Equivalent positions.

NB: The displayed values for the Cleared Product ID, Clearing Organization Identifier, and Execution Facility Indicators used in these 

data records may not be allowable values for these data elements, as defined in the Part 20 Data Dictionary. These data records reflect 

hypothetical cleared swap products and clearing/execution facilities, which necessitates the use of hypothetical values. All data records 

reported under Part 20 should only contain valid values for each respective data element, as noted in the Part 20 Data Dictionary.

For ease of visualization, the data records displayed in this section represent currency figures by using the $ sign. All data records 

submitted under Part 20 should display currencies using the ISO conventions noted in the Part 20 Data Dictionary.

Data records 1-3

In this example, data records 1-3 (shown below) resulted from swaps A, B, and C. Data record 1 shows the principal position of the swap 

dealer, SD1, on 9/01/2011 in uncleared heating oil swaps priced using the Platts Oilgram Price Report for New York No. 2 (Barge), and not 

transacted on an execution facility. The swap dealer’s principal position for this combination of reporting day, commodity, futures equivalent 

month, cleared/unclear status, execution status, and commodity reference price was 200.0000 Sep2011 long futures equivalent positions. 
Page 36

To determine that swaps A-C result in futures equivalent positions in the Sep 2011 heating oil contract, refer to the methodology established 

above for swaps not linked to a DCM contract. The contract specifications of swaps A-C indicate that the pricing of each swap will be the 

spot market price on the business day closest to September 15, 2011. Spot market transactions occurring on September 15th are partial 

substitutes to holding the September futures contract to delivery, which occurs from 9/09/2011-9/29/2011. For this reason, the futures 

equivalent positions resulting from swaps A-C are Sep 2011 futures equivalents, even though the last trading day of the Sep 2011 contract is 

8/31/2011.

To determine that SD1 held a position of 200.0000 long Sep 2011 NYMEX heating oil futures equivalents, first observe that SD1 is the fixed 

price payer for swaps A-C, and therefore has long price exposure. Each swap has one effective calculation period, so the total notional 

quantity of the swap is the notional quantity in that single calculation period. Swaps A and B both have a notional quantity of 2,100,000 U.S. 

gallons of heating oil. Because the NYMEX heating oil futures contract size is 42,000 U.S. gallons, the notional quantity of each swap results 

in a futures equivalent position of 50.0000 contracts. SD1 is counterparty to a swap with these specifications with both counterparties 

Energy_Firm_1 and Energy_Firm_2. Additionally, swap C, which is in all ways identical to swap B except for the notional quantity and the 

trade date, is also transacted at an earlier date between SD1 and Energy_Firm_2. The total notional quantity of this swap is 4,200,000 U.S. 

gallons of heating oil, or the equivalent of 100.0000 NYMEX heating oil contracts. 

Additionally note that Energy_Firm_1, perhaps because they conducted less business with SD1 in this example, receives a lower fixed price 

than Energy_Firm_2 receives. The fixed price, however, is not a field identified in the §20.3 or §20.4 data reports.

Similarly, data records 2 and 3 show the positions of SD1’s counterparties Energy_Firm_1 and Energy_Firm_2 in that same combination of 

reporting day, commodity, futures equivalent month, cleared/unclear status, execution status, and commodity reference price. Energy_Firm_1 

has a short futures equivalent position of 50.0000 and Energy_Firm_2 has a short futures equivalent position of 150.0000. 

Energy_Firm_1’s short position resulted from a single transaction previously discussed (swap A). Energy_Firm_2’s position resulted from 

two individual swap transactions, swaps B and C. If some feature of swap C had been different, for example if a different cash market price 

series was used to price the swap, the positions of Energy_Firm_2 resulting from swaps B and C would not be combined in a single data 

record. Additionally, a new data record would be required from SD1 to show its exposure in that heating oil swap. 

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 1 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 NYMEX HO 2011-09 False

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other 200.0000 0.0000 $26,040,000.00 $0.00

Data 

record 2 SD1 Counterparty CP_01 Energy_Firm_

1

2011-09-01 

17:00:00-05:00 NYMEX HO 2011-09 False

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other 0.0000 50.0000 $0.00 $6,510,000.00

Data 

record 3 SD1 Counterparty CP_02 Energy_Firm_2

2011-09-01 

17:00:00-05:00 NYMEX HO 2011-09 False

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other 0.0000 150.0000 $0.00 $19,530,000.00
Page 37

For the calculation of the notional value of the futures equivalent positions resulting from these swaps, assume on 9/01/2011 that the spot 

market price (Heating Oil-New York (Barge)-Platts U.S.) of heating oil was $3.1000 per gallon.

Data records 4-9

Data records 4 through 9 (shown below) contain positions of the swap dealer, SD1, and its counterparty, Energy_Firm_3, as a result of swap 

D. These positions are also in heating oil, but the commodity reference price and the futures equivalent month(s) are different than the 

positions displayed in data records 1-3. Swap D prices off one of the DCM contracts listed in §20.2, while swaps A-C priced off a cash 

market survey of the same commodity as swap D and in the same delivery location as specified in the DCM contract.

SD1 has a position of 350.0000 Oct 2011, Nov 2011, and Dec 2011 long futures contract equivalents, while Energy_Firm_3 holds the 

opposite positions. These positions resulted from swap D, in which SD1 is the fixed price payer and Energy_Firm_3 is the floating price 

payer. The total notional quantity of the swap is 44,100,000 U.S. gallons of No. 2 New York Harbor Heating Oil, although in this example 

there are three calendar-month long calculation periods, and therefore the notional quantity per calculation period is 14,700,000 U.S. gallons.

Because the NYMEX Heating Oil contract size is 42,000 U.S. gallons each calculation period corresponds to 350.0000 future equivalent 

contracts. Each calculation period is priced using the last day's next-to-expire futures contract settlement price during that calculation period, 

or September 30, 2011, October 31, 2011, November 30, 2011, respectively. These prices would result in positions in the October, November, 

and December heating oil contracts in 2011. 

Data records 4 through 9 display the manner in which a single swap transaction may result in multiple (six) position records under §20.4. In 

contrast, data records 1-3 resulted from three swap transactions. The position of SD1 resulting from swap D cannot be combined with SD1's 

positions resulting from swaps A, B, and C because the commodity reference price is different and the futures equivalent month also differs. 

Swaps A, B, C, and D are similar however, in that they are all uncleared, all result in heating oil positions, and are all executed without the 

use of an execution facility.

For the calculation of the notional value of the futures equivalent positions resulting from swap D, assume on 9/01/2011 that the price of the 

Oct 2011 heating oil futures contract settled at $3.1000 per gallon, and that the price of the Nov 2011 contract was $3.0000 per gallon, and 

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 4 SD1 Principal CP_00 SD1 2011-09-01 

17:00:00-05:00 NYMEX HO 2011-10 False HEATING OIL-NEW YORK-NYMEX Other 350.0000 0.0000 $45,570,000.00 $0.00

Data 

record 5 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 NYMEX HO 2011-11 False HEATING OIL-NEW YORK-NYMEX Other 350.0000 0.0000 $44,100,000.00 $0.00

Data 

record 6 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 NYMEX HO 2011-12 False HEATING OIL-NEW YORK-NYMEX Other 350.0000 0.0000 $42,630,000.00 $0.00

Data 

record 7 SD1 Counterparty CP_03 Energy_Firm_3

2011-09-01 

17:00:00-05:00 NYMEX HO 2011-10 False HEATING OIL-NEW YORK-NYMEX Other 0.0000 350.0000 $0.00 $45,570,000.00

Data 

record 8 SD1 Counterparty CP_03 Energy_Firm_

3

2011-09-01 

17:00:00-05:00 NYMEX HO 2011-11 False HEATING OIL-NEW YORK-NYMEX Other 0.0000 350.0000 $0.00 $44,100,000.00

Data 

record 9 SD1 Counterparty CP_03 Energy_Firm_3

2011-09-01 

17:00:00-05:00 NYMEX HO 2011-12 False HEATING OIL-NEW YORK-NYMEX Other 0.0000 350.0000 $0.00 $42,630,000.00
Page 38

that the price of Dec 2011 contract was $2.9000 per gallon.

Data records 10-11

Data records 10 and 11 (shown below) contain position records (from the perspective of SD1 only) resulting from a cleared swap (swap E) 

between SD1 and its clearing member counterparty, ABC_Clearing. It is important to note that other than the fact that the swap is cleared and 

centrally executed, it is otherwise quite similar to swap C, which also resulted in a position of 100.0000 long Sep 2011 futures contract 

equivalents. However, per the instructions in §20.4(b), SD1’s positions in otherwise similar cleared and uncleared swaps are not to be 

combined into a single data record, and are to instead be reported separately. The generation of futures equivalent positions and notional 

values is similar to the process discussed in data records 1-3.

SD1’s counterparty to this swap, ABC_Clearing, is a clearing member and therefore also required to submit position records under §20.4. In 

this example, the positions resulting from swap E would be reported by ABC_Clearing and perhaps combined with other like positions that 

the clearing member holds. When ABC_Clearing reports this swap from their perspective, they would identify that they hold as an Agent, and 

not as a Principal, a position of 100.0000 short Sep 2011 NYMEX HO futures equivalent positions. Likewise, ABC_Clearing would report 

SD1 as having a Customer, and not Counterparty, position of 100.0000 long Sep 2011 NYMEX HO futures equivalent positions. This 

alternative terminology would be employed to indicate the relationship between the clearing member and its customer.

Data records 12-17

Data records 12 through 17 (shown below) result from swaps F, G, and H. These are uncleared natural gas swaps between the swap dealer 

SD1 and counterparties XYZ_Firm, WVU_Firm, and Energy_Firm_1, respectively. The contract size for the NYMEX natural gas contract is 

10,000 MMBTU per month, therefore the total notional size of swaps F, G, and H is 250.0000, 75.0000, and 100.0000 futures equivalents, 

respectively.

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 10 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 CPID_04 NYMEX HO 2011-09 True CCO_ID_1

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other EX2 100.0000 0.0000 $12,600,000.00 $0.00

Data 

record 11 SD1 Counterparty CP_04 ABC_Clearing 2011-09-01 17:00:00-05:00 CPID_04 NYMEX HO 2011-09 True CCO_ID_1

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other EX2 0.0000 100.0000 $0.00 $12,600,000.00
Page 39

Swaps F, G, and H yield six position records on 9/01/2011 for a number of reasons. For one, these data records reflect a scenario where a 

principal or counterparty position may consist of both long and short futures equivalent positions. Second, two of the three swaps contributing 

to these data records generate futures equivalent positions in a single futures contract month, while the third generates futures equivalent 

positions in two futures contract months.

Swap F results in long futures equivalent positions of 125.0000 NYMEX natural gas Nov 2011 and Dec 2011 contracts for SD1, and opposite 

positions for the counterparty XYZ_Firm. XYZ_Firm’s positions are shown in data records 14 and 15. SD1’s Dec 2011 long position of 

125.0000 futures equivalents is shown in data record 13, and SD1’s 125.0000 Nov 2011 long futures equivalents resulting from Swap F are 

shown in data record 12, along with SD1’s long Nov 2011 position of 75.0000 NYMEX futures equivalents obtained from swap G.

Additionally, data record 12 shows SD1 with a short position of 100.0000 Nov-2011 NYMEX natural gas futures equivalents. This short 

position arises from swap H, where SD1 is floating price payer and the counterparty, Energy_Firm_1, is the fixed price payer. 

Energy_Firm_1’s position resulting from swap H is found in data record 17.

For the calculation of the notional value of the futures equivalent positions resulting from swaps F, G, and H, assume on 9/01/2011 that the 

price of the Nov 2011 natural gas futures contract settled at $4.5000 per MMBTU, and that the price of the Dec 2011 contract was $4.4000 

per MMBTU.

Data records 18-19

Data records 18 and 19 (shown below) result from swap I, which in this example is a natural gas swap transaction with optionality (also 

referred to as a swaption). In this example, assume the swaption cannot be exercised until 9/14/2011. 

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 12 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other 200.0000 100.0000 $9,000,000.00 $4,500,000.00

Data 

record 13 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 NYMEX NG 2011-12 False NATURAL GASNYMEX Other 125.0000 0.0000 $5,550,000.00 $0.00

Data 

record 14 SD1 Counterparty CP_05 XYZ_Firm 2011-09-01 

17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other 0.0000 125.0000 $0.00 $5,625,000.00

Data 

record 15 SD1 Counterparty CP_05 XYZ_Firm 2011-09-01 17:00:00-05:00 NYMEX NG 2011-12 False NATURAL GASNYMEX Other 0.0000 125.0000 $0.00 $5,550,000.00

Data 

record 16 SD1 Counterparty CP_06 WVU_Firm 2011-09-01 17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other 0.0000 75.0000 $0.00 $3,375,000.00

Data 

record 17 SD1 Counterparty CP_01 Energy_Firm_1

2011-09-01 

17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other 100.0000 0.0000 $4,500,000.00 $0.00

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 18 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other Call 2011-09-14

$4.5000 

per 

MMBTU

Standard 0.0000 100.0000 0.0000 90.0000 $0.00 $4,500,000.00

Data 

record 19 SD1 Counterparty CP_07 Energy_Firm_1

2011-09-01 

17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other Call 2011-09-14

$4.5000 

per 

MMBTU

Standard 100.0000 0.0000 90.0000 0.0000 $4,500,000.00 $0.00
Page 40

Assume in this example that the delta factor on this option is .9, as the settlement price on 9/01/2011 is $5.0000 per MMBTU and the 

swaption strike is $4.5000 per MMBTU. However, the swaption does not expire until 9/14/2011, so there is a small chance that the swaption 

may expire out of the money. 

Because the swaption is trading close to parity, the non-delta adjusted and the delta-adjusted positions are not very different. If the swaption 

delta had been one, then the delta adjusted swaption positions would be the same as the non-delta adjusted swaption positions.

As in previous examples, for the calculation of the notional value of the futures equivalent positions resulting from swap I assume on 

9/01/2011 that the price of the Nov 2011 natural gas futures contract settled at $5.0000 per MMBTU. Multiply this value by the delta-adjusted 

positions to calculate the notional values.

Data records 20-25

Swap J results in data records 20-25 (shown below). The calculation of the futures equivalent positions resulting from swap J is more 

complex than in previously discussed swaps. Swap J is a cleared soybean swap between SD1 and CP_10, although these entities are 

anonymously matched at the execution facility. Assume that SD1 and its non-reporting counterparty (CP_10) both use CM1 as their clearing 

member. Swap J has three calculation periods, each one calendar month in length. Furthermore, the floating price is calculated as the 

arithmetic average of the daily next-to-expire futures price across each calculation period.*

As was the case with data records 10-11, SD1 reports their position as principal and their clearing member (CM1) as having a counterparty 

position. If CM1 were to report this trade, they would reference SD1’s position as customer and their long positions as being agent positions.

 * For an example of the futures equivalent conversion of a similar average price swap, please refer to Example 1 of Appendix A to the Commission's Final Rule for Part 

20, as published in the Federal Register, and available here: http://www.cftc.gov/ucm/groups/public/@lrfederalregister/documents/file/2011-18054a.pdf

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 20 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 CDIP_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 46.6667 $0.00 $3,266,900.00

Data 

record 21 SD1 Principal CP_00 SD1 2011-09-01 

17:00:00-05:00 CDIP_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 200.0000 $0.00 $14,500,000.00

Data 

record 22 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 CDIP_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 53.3333 $0.00 $3,999,750.00

Data 

record 23 SD1 Counterparty CP_08 CM1 2011-09-01 17:00:00-05:00 CDIP_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 46.6667 0.0000 $3,266,900.00 $0.00

Data 

record 24 SD1 Counterparty CP_08 CM1 2011-09-01 17:00:00-05:00 CDIP_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 200.0000 0.0000 $14,500,000.00 $0.00

Data 

record 25 SD1 Counterparty CP_08 CM1 2011-09-01 

17:00:00-05:00 CDIP_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 53.3333 0.0000 $3,999,750.00 $0.00
Page 41

Because the CBOT soybean contract has a size of 5,000 bushels, and the total notional quantity of the swap is 1,500,000 bushels, the notional 

quantity of swap J per calculation period on 9/01/2011 equals 500,000 bushels, or 100.0000 futures contract equivalents.

Determining the futures equivalent month(s) for an average price swap like swap J necessitates referencing the product calendar of the 

relevant futures contract. The first calculation period spans September 01, 2011 through September 30, 2011. The 30 daily settlement prices 

across this calculation period do not correspond to a single futures equivalent month; instead the next-to-expire CBOT soybean futures 

contract is the Sep 2011 contract during the September 01-September 14 time period. From September 15-September 30, when the first 

calculation period of swap J is over, the next-to-expire CBOT soybean futures contract is the Nov-2011 contract. Therefore, on 9/01/2011, 

14/30ths of futures equivalent positions of the notional quantity assigned to the first calculation period are assigned to the Sep 2011 contract 

month while 16/30ths of the notional quantity are assigned to the Nov 2011 contract month.

Further translated into futures equivalents, on 9/01/2011 the first calculation period of swap J results in 46.6667 Sep 2011 futures equivalent 

positions and 53.3333 Nov 2011 futures equivalents.

Similarly, the second calculation period spans October 01, 2011 through October 31, 2011. The next-to-expire futures contract during this 

entire calculation period is the Nov 2011 futures contract (the CBOT does not list an October futures contract). The full notional quantity of 

the second calculation period is therefore priced using the Nov 2011 futures contract, and the resulting futures equivalent position on 

9/01/2011 is 100.0000.

The third calculation period of swap J spans November 01, 2011 through November 30, 2011. The next-to-expire futures contract is the Nov

2011 contract up until it settles on 11/14/2011. Thereafter, for the remaining pricing days in November, the next-to-expire futures contract is 

the Jan 2012 contract (the CBOT does not list a December futures contract). Accordingly, on 9/01/2011, 14/30th of the notional quantity of 

the third calculation period are reported as Nov 2011 futures equivalent positions (46.6667 contracts), and 16/30ths are reported as Jan 2012 

futures equivalent positions (53.3333 contracts). 

When SD1 reports its principal and counterparty positions for swap J on 9/01/2011, it will therefore report a short principal position of 

46.6667 Sep 2011 futures equivalent positions, 200.0000 Nov 2011 futures equivalent positions, and 53.3333 Jan 2012 futures equivalent 

positions. The counterparty to swap J, CM1, will be shown to have the opposite position from SD1. The futures equivalent position of 

200.0000 Nov 2011 contracts results from all three calculation periods of the swap. 

Because this swap is brought to clearing, SD1 would report CM1 as the counterparty instead of the original counterparty to the swap CP_10. 

If CP_10 was also a reporting entity, they would likewise report CM1 as their counterparty. The clearing process essentially produces two 

transactions with the clearing member on the long side and the short side, standing between the original counterparties to the swap.

For the calculation of the notional value of the futures equivalents of swap J on 9/01/2011, assume that the Sep 2011 contract price is 1400 

cents per bushel, the Nov 2011 contract price is 1450 cents per bushel, and the Jan 2011 contract price is 1500 cents per bushel. Accordingly, 
Page 42

the notional values of the futures equivalent positions discussed in the previous paragraph are $3,266,900.00 for the 46.6667 Sep 2011 

contracts, $14,500,000.00 for the 200.0000 Nov 2011 contracts, and $3,999,750.00 for the 53.3333 Jan 2012 contracts.

Data records 26-27

Data records 26 and 27 (shown below) display the principal and counterparty positions resulting from a daily natural gas swap (swap K). This 

swap is transacted on August 31, 2011, and is solely priced off the published price of the Platts Gas Daily Henry Hub on September 01, 2011. 

Because the September NG contract delivers on September 01, 2011, the positions resulting from this daily swap would be Sep 2011 futures 

equivalents. Furthermore, although swap K is a daily swap, the particular day of its expiration is not included in the futures equivalent month 

and year field. Instead, the position resulting from this one particular swap would only be reported for a single reporting day.

As in previous examples, for the calculation of the notional value of the futures equivalent positions resulting from swap K assume on 

9/01/2011 that the price of the natural gas cash market survey was $4.5000 per MMBTU.

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 26 SD1 Principal CP_00 SD1 2011-09-01 17:00:00-05:00 NYMEX NG 2011-09 False

NATURAL GASLOUISANA (HENRY 

HUB)-GAS DAILY

Other 0.0000 100.0000 $0.00 $4,500,000.00

Data 

record 27 SD1 Counterparty CP_02 Energy_Firm_2

2011-09-01 

17:00:00-05:00 NYMEX NG 2011-09 False

NATURAL GASLOUISANA (HENRY 

HUB)-GAS DAILY

Other 100.0000 0.0000 $4,500,000.00 $0.00
Page 43

Data records 28-52

Data records 28-52 (shown below) display the same information as displayed in data records 1-27, which pertain to the positions resulting 

from swap transactions A-K, but on the following reporting day (9/02/2011) as they would be reported by swap dealer SD1. All of the data 

records are unchanged except data records 46 and 49, which correspond to data records 20 and 23. Additionally, data records 26 and 27 have 

no equivalent on 9/02/2011 because they represent positions from a daily swap (swap K), and the swap is no longer open on 9/02/2011 and 

therefore there are no associated positions.

Data records 47 and 50 show smaller principal and counterparty positions than shown on 9/01/2011 (in data records 20 and 23), for the reason 

that these swaps involved average pricing. Recall from the earlier discussion of swap J that the futures equivalent positions result from the 

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 28 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 NYMEX HO 2011-09 False

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other 200.0000 0.0000 $26,040,000.00 $0.00

Data 

record 29 SD1 Counterparty CP_01 Energy_Firm_1

2011-09-02 

17:00:00-05:00 NYMEX HO 2011-09 False

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other 0.0000 50.0000 $0.00 $6,510,000.00

Data 

record 30 SD1 Counterparty CP_02 Energy_Firm_2

2011-09-02 

17:00:00-05:00 NYMEX HO 2011-09 False

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other 0.0000 150.0000 $0.00 $19,530,000.00

Data 

record 31 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 NYMEX HO 2011-10 False HEATING OIL-NEW YORK-NYMEX Other 350.0000 0.0000 $45,570,000.00 $0.00

Data 

record 32 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 NYMEX HO 2011-11 False HEATING OIL-NEW YORK-NYMEX Other 350.0000 0.0000 $44,100,000.00 $0.00

Data 

record 33 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 NYMEX HO 2011-12 False HEATING OIL-NEW YORK-NYMEX Other 350.0000 0.0000 $42,630,000.00 $0.00

Data 

record 34 SD1 Counterparty CP_03 Energy_Firm_

3

2011-09-02 

17:00:00-05:00 NYMEX HO 2011-10 False HEATING OIL-NEW YORK-NYMEX Other 0.0000 350.0000 $0.00 $45,570,000.00

Data 

record 35 SD1 Counterparty CP_03 Energy_Firm_3

2011-09-02 

17:00:00-05:00 NYMEX HO 2011-11 False HEATING OIL-NEW YORK-NYMEX Other 0.0000 350.0000 $0.00 $44,100,000.00

Data 

record 36 SD1 Counterparty CP_03 Energy_Firm_3

2011-09-02 

17:00:00-05:00 NYMEX HO 2011-12 False HEATING OIL-NEW YORK-NYMEX Other 0.0000 350.0000 $0.00 $42,630,000.00

Data 

record 37 SD1 Principal CP_00 SD1 2011-09-02 

17:00:00-05:00 CPID_04 NYMEX HO 2011-09 True CCO_ID_1

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other EX2 100.0000 0.0000 $12,600,000.00 $0.00

Data 

record 38 SD1 Counterparty CP_04 ABC_Clearing 2011-09-02 17:00:00-05:00 CPID_04 NYMEX HO 2011-09 True CCO_ID_1

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

Other EX2 0.0000 100.0000 $0.00 $12,600,000.00

Data 

record 39 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other 200.0000 100.0000 $9,000,000.00 $4,500,000.00

Data 

record 40 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 NYMEX NG 2011-12 False NATURAL GASNYMEX Other 125.0000 0.0000 $5,550,000.00 $0.00

Data 

record 41 SD1 Counterparty CP_05 XYZ_Firm 2011-09-02 17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other 0.0000 125.0000 $0.00 $5,625,000.00

Data 

record 42 SD1 Counterparty CP_05 XYZ_Firm 2011-09-02 17:00:00-05:00 NYMEX NG 2011-12 False NATURAL GASNYMEX Other 0.0000 125.0000 $0.00 $5,550,000.00

Data 

record 43 SD1 Counterparty CP_06 WVU_Firm 2011-09-02 17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other 0.0000 75.0000 $0.00 $3,375,000.00

Data 

record 44 SD1 Counterparty CP_01 Energy_Firm_1

2011-09-02 

17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other 100.0000 0.0000 $4,500,000.00 $0.00

Data 

record 45 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other Call 2011-09-14

$4.5000 

per 

MMBTU

Standard 0.0000 100.0000 0.0000 90.0000 $0.00 $4,500,000.00

Data 

record 46 SD1 Counterparty CP_07 Energy_Firm_1

2011-09-02 

17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX Other Call 2011-09-14

$4.5000 

per 

MMBTU

Standard 100.0000 0.0000 90.0000 0.0000 $4,500,000.00 $0.00

Data 

record 47 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 CDIP_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 43.3333 $0.00 $3,033,100.00

Data 

record 48 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 CDIP_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 200.0000 $0.00 $14,500,000.00

Data 

record 49 SD1 Principal CP_00 SD1 2011-09-02 17:00:00-05:00 CDIP_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 53.3333 $0.00 $3,999,750.00

Data 

record 50 SD1 Counterparty CP_08 CM1 2011-09-02 17:00:00-05:00 CDIP_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 43.3333 0.0000 $3,033,100.00 $0.00

Data 

record 51 SD1 Counterparty CP_08 CM1 2011-09-02 

17:00:00-05:00 CDIP_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 200.0000 0.0000 $14,500,000.00 $0.00

Data 

record 52 SD1 Counterparty CP_08 CM1 2011-09-02 17:00:00-05:00 CDIP_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 53.3333 0.0000 $3,999,750.00 $0.00
Page 44

daily average settlements of multiple futures contract months in three calculation periods. On 9/02/2011, only the Sep-2011 futures equivalent 

position has changed relative to the day before; the Nov-2011 and Jan-2011 futures equivalent positions are the same as previously reported. 

The Sep-2011 futures equivalent position now corresponds to 13 of the 30 total pricing days that correspond to the first calculation period, 

and therefore the Sep-2011 futures equivalent position is 43.3333 contracts.

Further assume that the spot or futures settlement price of all reference prices is the same on 9/02/2011 as on 9/01/2011, and therefore there is 

no change in the notional value of the reported positions.

Data records 53-70

Data records 53-70 (shown below) display the position reports generated by clearing member CM1 for report date 9/01/2011 and 9/02/2011 

based on swap J. Assume CM1 has no other open paired swaps other than swap J. Recall that CM1 is the clearing member for both SD1 and 

CP_10, the ultimate counterparties to that cleared swap once they are matched at the trading venue.

As such, CM1 reports data records 53-55 and 62-64 for its agent positions, and the other data records pertain to the positions of the original 

counterparties to the swap, SD1 and CP_10. From the perspective of CM1, these two customers are the beneficial owners of positions traded 

and cleared, and they are identified using the 102S Swap Counterparty ID and Counterparty Name fields as established by CM1. Accordingly, 

CM1 will use a different 102S Identifier for SD1 than SD1 uses to identify itself; 102S Identifiers are created by and specific to each 

reporting entity, so this arrangement is expected. Similarly, CM1 uses a different 102S Identifier for its agent positions than SD1 used when 

reporting CM1 as a counterparty.
Page 45

Data records 71-78 

Data records 71-78 (shown below) display positions of a clearing member (EF2) with its counterparty (BF1), as a result from Swap L, which 

is an uncleared swap. While many may casually refer to a product like this a spread swap, this product does not meet the definition of a 

“TwoComponentIntercommoditySpread” because it results in more than two exposures. As such, the positions resulting from this swap are 

designed as “Other” in the Position Type Indicator field.

While only the exposure of the CMX Gold portion of the swap renders this transaction a paired swap, consistent with the guidance provided 

above, the reporting entity, EF2 in this instance, could provide data records to the Commission that show both the gold and Eurodollar 

positions resulting from this inter-commodity spread transaction. As a result, swap L results in 8 data records for the first reporting day, 

September 27, 2011. 

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 53 CM1 Agent CM_00 CM1 2011-09-01 

17:00:00-05:00 CPID_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 46.6667 46.6667 $3,266,900.00 $3,266,900.00

Data 

record 54 CM1 Agent CM_00 CM1 2011-09-01 17:00:00-05:00 CPID_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 200.0000 200.0000 $14,500,000.00 $14,500,000.00

Data 

record 55 CM1 Agent CM_00 CM1 2011-09-01 17:00:00-05:00 CPID_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 53.3333 53.3333 $3,999,750.00 $3,999,750.00

Data 

record 56 CM1 Customer SD1 CP_AB 2011-09-01 17:00:00-05:00 CPID_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 46.6667 $0.00 $3,266,900.00

Data 

record 57 CM1 Customer SD1 CP_AB 2011-09-01 17:00:00-05:00 CPID_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 200.0000 $0.00 $14,500,000.00

Data 

record 58 CM1 Customer SD1 CP_AB 2011-09-01 

17:00:00-05:00 CPID_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 53.3333 $0.00 $3,999,750.00

Data 

record 59 CM1 Customer CP_10 CP_10 2011-09-01 17:00:00-05:00 CPID_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 46.6667 0.0000 $3,266,900.00 $0.00

Data 

record 60 CM1 Customer CP_10 CP_10 2011-09-01 17:00:00-05:00 CPID_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 200.0000 0.0000 $14,500,000.00 $0.00

Data 

record 61 CM1 Customer CP_10 CP_10 2011-09-01 17:00:00-05:00 CPID_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 53.3333 0.0000 $3,999,750.00 $0.00

Data 

record 62 CM1 Agent CM_00 CM1 2011-09-02 17:00:00-05:00 CPID_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 43.3333 43.3333 $3,033,100.00 $3,033,100.00

Data 

record 63 CM1 Agent CM_00 CM1 2011-09-02 17:00:00-05:00 CPID_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 200.0000 200.0000 $14,500,000.00 $14,500,000.00

Data 

record 64 CM1 Agent CM_00 CM1 2011-09-02 

17:00:00-05:00 CPID_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 53.3333 53.3333 $3,999,750.00 $3,999,750.00

Data 

record 65 CM1 Customer SD1 CP_AB 2011-09-02 17:00:00-05:00 CPID_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 43.3333 $0.00 $3,033,100.00

Data 

record 66 CM1 Customer SD1 CP_AB 2011-09-02 

17:00:00-05:00 CPID_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 200.0000 $0.00 $14,500,000.00

Data 

record 67 CM1 Customer SD1 CP_AB 2011-09-02 

17:00:00-05:00 CPID_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 0.0000 53.3333 $0.00 $3,999,750.00

Data 

record 68 CM1 Customer CP_10 CP_10 2011-09-02 17:00:00-05:00 CPID_08 CBT S 2011-09 True CCO_ID_2 SOYBEANS-CBOT Other EX2 43.3333 0.0000 $3,033,100.00 $0.00

Data 

record 69 CM1 Customer CP_10 CP_10 2011-09-02 

17:00:00-05:00 CPID_08 CBT S 2011-11 True CCO_ID_2 SOYBEANS-CBOT Other EX2 200.0000 0.0000 $14,500,000.00 $0.00

Data 

record 70 CM1 Customer CP_10 CP_10 2011-09-02 17:00:00-05:00 CPID_08 CBT S 2012-01 True CCO_ID_2 SOYBEANS-CBOT Other EX2 53.3333 0.0000 $3,999,750.00 $0.00
Page 46

In Swap L, EF2 pays to BF1 the difference in Eurodollar contract settlements and BF1 pays to EF2 the difference in gold contract settlements. 

Since the notional quantity of the swap is $100,000,000 for each quarterly payment (delivery) and the contract size of the CMX Gold contract 

is 100 troy oz, EF2 has a position of long 559.9104 Dec 2013 and short 579.3743 Dec 2012 contracts, while BF1 holds the opposite positions 

(100,000,000 / (settlement price of GCZ12 * 100) and 100,000,000 / (settlement price of GCZ13 * 100)). 

Because the Eurodollar position records reported from this swap do not correspond to any contract listed in § 20.2, the positions are 

designated with the appropriate Price Reference Month and Year, instead of a Futures Equivalent Month and Year. For the calculation of 

notional values and futures equivalent positions, assume the settlement price for Dec 2012 is $1726.0000 per troy oz. and the settlement price 

for Dec 2013 is $1786.0000 per troy oz. Because of the prescribed position reporting methodology, the notional value of the positions 

resulting from this swap is much larger that the net exposure of this swap to each counterparty. This will be the case with most swaps that 

involve the difference between different prices. 

Data records 79-102 

Data records 79-102 (shown below) contain positions of a clearing member (EF1) with its counterparty (SD1), as a result from Swap M. 

Since this trade results in exposure for each calendar month of 2012, 24 data records (one for each combination of month and counterparty to 

the transaction) are transmitted to the Commission. Data records 79-102 simply show swap M from the perspective of CM1 acting as agent to 

its customer, SD1. SD1, as a reporting entity, would also be expected to provide reports on positions from swap M from its perspective as 

principal and with its clearing member CM1 as counterparty.

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility Long Swap Position Short Swap Position Put/Call Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption Notional 

Value Position

Data 

record 71 EF2 Principal CP_33 EF2 2011-09-27 17:00:00-05:00 CMX GC 2012-12 False GOLD-COMEX Other 0.0000 579.3743 $0.00 $100,000,000.00

Data 

record 72 EF2 Principal CP_33 EF2 2011-09-27 17:00:00-05:00 CMX GC 2013-12 False GOLD-COMEX Other 559.9104 0.0000 $100,000,000.00 $0.00

Data 

record 73 EF2 Principal CP_33 EF2 2011-09-27 17:00:00-05:00 Other 2012-12 False EURODOLLARS-CME Other $0.0000 $100,000,000.0000 $0.00 $100,000,000.00

Data 

record 74 EF2 Principal CP_33 EF2 2011-09-27 17:00:00-05:00 Other 2013-12 False EURODOLLARS-CME Other $100,000,000.0000 $0.0000 $100,000,000.00 $0.00

Data 

record 75 EF2 Counterparty CP_45 BF1 2011-09-27 17:00:00-05:00 CMX GC 2012-12 False GOLD-COMEX Other 579.3743 0.0000 $100,000,000.00 $0.00

Data 

record 76 EF2 Counterparty CP_45 BF1 2011-09-27 17:00:00-05:00 CMX GC 2013-12 False GOLD-COMEX Other 0.0000 559.9104 $0.00 $100,000,000.00

Data 

record 77 EF2 Counterparty CP_45 BF1 2011-09-27 

17:00:00-05:00 Other 2012-12 False EURODOLLARS-CME Other $100,000,000.0000 $0.0000 $100,000,000.00 $0.00

Data 

record 78 EF2 Counterparty CP_45 BF1 2011-09-27 17:00:00-05:00 Other 2013-12 False EURODOLLARS-CME Other $0.0000 $100,000,000.0000 $0.00 $100,000,000.00
Page 47

In this example, on September 1, 2011, the settlement price of NYMEX NG for the JAN 2012 – JUN 2012 contracts is $4.5000 per MMBtu. 

This example assumes that this price leads the option with a strike price of $4.5000 to have a delta factor of .8. The settlement price for JUL 

2012 – DEC 2012 is $4.2500. This led the option’s delta to be .4 for those months. 

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 79 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-01 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2011-12-28

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 20.0000 0.0000 $900,000.00 $0.00

Data 

record 80 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-02 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-01-27

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 20.0000 0.0000 $900,000.00 $0.00

Data 

record 81 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-03 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-02-27

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 20.0000 0.0000 $900,000.00 $0.00

Data 

record 82 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-04 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-03-28

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 20.0000 0.0000 $900,000.00 $0.00

Data 

record 83 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-05 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-04-26

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 20.0000 0.0000 $900,000.00 $0.00

Data 

record 84 EF1 Agent CP_51 EF1 2011-09-01 

17:00:00-05:00 QHH NYMEX NG 2012-06 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-05-29

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 20.0000 0.0000 $900,000.00 $0.00

Data 

record 85 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-07 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-06-27

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 10.0000 0.0000 $425,000.00 $0.00

Data 

record 86 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-08 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-07-27

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 10.0000 0.0000 $425,000.00 $0.00

Data 

record 87 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-09 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-08-29

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 10.0000 0.0000 $425,000.00 $0.00

Data 

record 88 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-10 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-09-26

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 10.0000 0.0000 $425,000.00 $0.00

Data 

record 89 EF1 Agent CP_51 EF1 2011-09-01 

17:00:00-05:00 QHH NYMEX NG 2012-11 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-10-29

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 10.0000 0.0000 $425,000.00 $0.00

Data 

record 90 EF1 Agent CP_51 EF1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-12 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-11-28

$4.5000 

per 

MMBTU

Standard 25.0000 0.0000 10.0000 0.0000 $425,000.00 $0.00

Data 

record 91 EF1 Customer CP_00 SD1 2011-09-01 

17:00:00-05:00 QHH NYMEX NG 2012-01 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2011-12-28

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 20.0000 $0.00 $900,000.00

Data 

record 92 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-02 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-01-27

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 20.0000 $0.00 $900,000.00

Data 

record 93 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-03 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-02-27

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 20.0000 $0.00 $900,000.00

Data 

record 94 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-04 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-03-28

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 20.0000 $0.00 $900,000.00

Data 

record 95 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-05 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-04-26

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 20.0000 $0.00 $900,000.00

Data 

record 96 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-06 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-05-29

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 20.0000 $0.00 $900,000.00

Data 

record 97 EF1 Customer CP_00 SD1 2011-09-01 

17:00:00-05:00 QHH NYMEX NG 2012-07 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-06-27

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 10.0000 $0.00 $425,000.00

Data 

record 98 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-08 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-07-27

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 10.0000 $0.00 $425,000.00

Data 

record 99 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-09 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-08-29

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 10.0000 $0.00 $425,000.00

Data 

record 100 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-10 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-09-26

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 10.0000 $0.00 $425,000.00

Data 

record 101 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-11 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-10-29

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 10.0000 $0.00 $425,000.00

Data 

record 102 EF1 Customer CP_00 SD1 2011-09-01 17:00:00-05:00 QHH NYMEX NG 2012-12 True CCO_ID_2 NATURAL GASNYMEX Other SEF2 Call 2012-11-28

$4.5000 

per 

MMBTU

Standard 0.0000 25.0000 0.0000 10.0000 $0.00 $425,000.00
Page 48

On September 1, 2011, EF1 has long exposure to each contract month of the NYMEX NG commodity and SD1 has short exposure. The nondelta adjusted position in each futures equivalent month is 25.0000. This is because each futures equivalent month has a notional quantity of 

250,000 MMBtu and the size of the NYMEX NG contract is 10,000 MMBtu.

To find the delta-adjusted positions, the reporting entity adjusted the non-delta adjusted position in each futures equivalent month by the 

appropriate delta factor for that month. For the JAN 2012 futures equivalent month, the calculation was 

([25.0000 non-delta adjusted position]*[.8(delta factor)] = [20.0000 delta-adjusted positions]).

As these options are European style, they cannot be exercised before the expiration date of the option. Therefore, EF1 and SD1 will continue 

to have their positions reported in the swaptions fields until the expiration of each option. 

Data records 103-106 

Data records 103-106 (shown below) display the position reports generated by swap dealer SD3 for report date 9/01/2011 as a result of swap 

N, which is a commodity index swap where all of the exposures generated from the swap are reported in separate data records. Swap N 

qualified as a commodity index transaction because its settlement is based on two distinct commodities, and the settlement does not involve 

the difference in price between those two commodities.

Because one of the two commodities included in this swap (jet fuel) is not represented in § 20.2, the value for the Commodity data element 

should indicate “Other” for those data records pertaining to jet fuel positions. The Commodity Reference Price should indicate the price series 

used for each commodity exposure. Additionally, all data records resulting from this swap should indicate that they are Index, as shown in the 

Position Type Indicator field.

The futures equivalent month for the jet fuel positions includes the indicator for the Price Reference Month of September, reflecting the fact 

that there is no futures equivalent contract listed in § 20.2 but that instead the pricing for the jet fuel component of this commodity index swap 

occurred during that calendar month.

Similarly to the abovementioned issue regarding the futures equivalent month, the long and short positions shown for the jet fuel components 

of this commodity index swap cannot be displayed as the number of lots of some contract listed in § 20.2. Instead, the notional size of that 

component of the index is to be reported. The units that commodity is customarily priced in should be displayed as well. In this case, the 

100,000 gallons of jet fuel used in the pricing of the commodity index swap are displayed in lieu of futures equivalent positions.

For the calculation of the notional value of the futures equivalent month and price reference month positions resulting from these swaps, 

assume on 9/01/2011 that the spot market price of heating oil was $3.1000 per gallon and the spot market price of jet fuel was $3.3000 per 

gallon.
Page 49

Data records 107-110

Data records 107-110 (shown below) display the position records generated by CM1 for report date 9/1/2011 based on swap O, a Basis swap 

transacted on ICE and cleared at ICE Clear Europe Limited. As this swap is centrally executed and then cleared by CM1 on behalf of its 

customer Gas Company Inc, CM1 reports positions with the Agent and Customer affiliations. 

As per the guidance in the above note on reporting basis swaps, the Position Type Indicator should be marked with a 

‘TwoComponentLocationalBasis’ for all position records that are generated from this swap. It is recommended that reporting entities 

decompose the exposures generated from this swap into the relevant NYMEX NG and Houston Ship Channel natural gas positions.

For the calculation of the notional value of the futures equivalent positions resulting from these swaps, assume on 9/1/2011that the NYMEX 

natural gas contract settled at $3.5000 per MMBTU and the spot market price of natural gas at Houston Ship Channel was $3.6000 per 

MMBTU.

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility

Long Swap 

Position

Short Swap 

Position

Put/Call 

Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption 

Notional Value 

Position

Data 

record 103 SD3 Principal CP_10 SD3 2011-09-01 17:00:00-05:00 NYMEX HO 2011-09 False

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

IndexOrBasket 0.0000 10.0000 $0.00 $1,302,000.00

Data 

record 104 SD3 Principal CP_10 SD3 2011-09-01 17:00:00-05:00 Other 2011-09 False

JET FUEL-NEW 

YORK (BARGE)-

PLATTS U.S. 

IndexOrBasket 0.0000 Gallons 100,000.0000 

Gallons $0.00 $330,000.00

Data 

record 105 SD3 Counterparty CP_13 AIRLINE1 2011-09-01 17:00:00-05:00 NYMEX HO 2011-09 False

HEATING OIL-NEW 

YORK (BARGE)-

PLATTS U.S. 

IndexOrBasket 10.0000 0.0000 $1,302,000.00 $0.00

Data 

record 106 SD3 Counterparty CP_13 AIRLINE1 2011-09-01 17:00:00-05:00 Other 2011-09 False

JET FUEL-NEW 

YORK (BARGE)-

PLATTS U.S. 

IndexOrBasket 100,000.0000 

Gallons 0.0000 Gallons $330,000.00 $0.00

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility Long Swap Position Short Swap Position Put/Call Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption Notional 

Value Position

Data 

record 107 CM1 Agent CM_00 CM1 2011-09-01 

17:00:00-05:00 HXS NYMEX NG 2011-10 True ICEU NATURAL GASNYMEX

TwoComponentL

ocationalBasis ICE 0.0000 10.0000 $0.00 $350,000.00

Data 

record 108 CM1 Agent CM_00 CM1 2011-09-01 17:00:00-05:00 HXS NYMEX NG 2011-10 True ICEU

NATURAL GAS-E. 

TEXAS (HOUSTON 

SHIP CHANNEL)-

INSIDE FERC

TwoComponentL

ocationalBasis ICE 10.0000 0.0000 $360,000.00 $0.00

Data 

record 109 CM1 Customer CP_50 Gas Company Inc

2011-09-01 

17:00:00-05:00 HXS NYMEX NG 2011-10 True ICEU NATURAL GASNYMEX

TwoComponentL

ocationalBasis ICE 10.0000 0.0000 $350,000.00 $0.00

Data 

record 110 CM1 Customer CP_50 Gas Company Inc

2011-09-01 

17:00:00-05:00 HXS NYMEX NG 2011-10 True ICEU

NATURAL GAS-E. 

TEXAS (HOUSTON 

SHIP CHANNEL)-

INSIDE FERC

TwoComponentL

ocationalBasis ICE 0.0000 10.0000 $0.00 $360,000.00
Page 50

Data records 111-112 and 113-120

Data records 111-112 (shown below) display positions on 9/20/2011 of a swap dealer (SD5) and its Pension Fund counterparty in an 

uncleared commodity index swap (swap P) that is reported in units of the Diversified Commodity Index. Data records 113-120 (also shown 

below) display positions on the same reporting day resulting from the same swap transacted by the same counterparties, but instead display 

the resulting underlying positions of the Diversified Commodity Index in question, as reporting entities may choose to decompose and 

separately report the exposures from such products. 

In contrast to swap N, which was customized and privately-created and therefore not a commonly-know commodity index, swap P involves 

the Dow Jones-UBS Energy Total Return Sub-IndexSM (DJ-UBS CITREN; Bloomberg ticker: DJUBENTR), which meets the definition of a 

Diversified Commodity Index in § 20.1. The commodity components of this index are natural gas, crude oil, unleaded gasoline, and heating 

oil. Data records associated with this swap should indicate "IndexOrBasket" in the Position Type Indicator field.

Disclaimer: Please note that this example only makes reference to and discusses the name, Bloomberg ticker, and commodity components of 

a Dow Jones index product. The actual component weightings, settlement prices of underlying instruments, and index values are not 

referenced. Instead, this example makes use of hypothetical values for these variables, as shown in the table below. 

The base component weightings of the index in question are recalculated annually, and as such they are the same on all reporting days in 

2011. Assume that the published value of the index was 230.2678 on 9/20/2011. Each energy component is priced using the “lead future” 

contract, as defined by Dow Jones for the creation of this index. As such, on 9/20/2011 the index value is calculated using the November 

futures contract for all of the four energy commodity components of this index. However, when this index product is reported as a position in 

the full diversified index, the Price Reference Month would indicate September 2011, as this is the month during which the index position is 

held and the pricing occurs. If the index swap were to be held into additional calendar months, those Price Reference Months would also be 

reportable.

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility Long Swap Position Short Swap Position Put/Call Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption Notional 

Value Position

Data 

record 111 SD5 Principal CP_ZZ SD5 2011-09-20 17:00:00-05:00 Index 2011-09 False DJUBENTR IndexOrBasket $0.0000 $230,267.8373 $0.00 $230,267.84

Data 

record 112 SD5 Counterparty CP_AB PENSION FUND

2011-09-20 

17:00:00-05:00 Index 2011-09 False DJUBENTR IndexOrBasket $230,267.8373 $0.0000 $230,267.84 $0.00
Page 51

Swap P Index Component Values for Data Records 113-120; Values for 9/20/2011

Index 

Commodity 

Components

Baseline Values for 2011 Values on 9/20/2011

Component 

Weighting*

Settlement

Price*

Index Component 

Multiplier*

Component 

Weighting*

Settlement

Price*

Weighted Component 

Values*

Crude Oil (CL) 30% $75.0000 5.00 30% $80.0000 400.00

Natural Gas (NG) 30% $4.2500 88.24 30% $4.0500 357.36

Heating Oil (HO) 20% $3.7500 66.67 20% $3.5000 233.33

Unleaded Gasoline (RB) 20% $3.5000 71.43 20% $3.5500 253.57

Total Index 100% NA 231.33 100% NA 230.2678373

* = Hypothetical Value; 2011 Base WAV1* = 1.25

In this example, the counterparties to the swap have agreed to make the notional quantity of the swap 1000 times the value of the index. As 

such, when the exposures from the swap are decomposed for the 9/20/2011 report date, the following procedure is used. First, the value of the 

index on that day is multiplied by 1000, as per the terms of the swap. On 9/20/2011, this yields $230,267.8373.

On 9/20/2011, we know that (400.0000/1244.2577 = .3214) around 32% of the exposure results from the crude oil component of the swap. 

Note how the crude oil component was originally 30% of the index, but because the price of crude has risen on 9/20/2011 relative to the other 

original prices of energy components in the index, on this day the crude weighting in the index is above the initial value. Similarly, on 

9/20/2011, the index exposure for natural gas is around 29% (357.3529/1244.2577 = .2872), the index exposure for heating oil is around 19% 

(233.3333/1244.2577 = .1875), and the index exposure for unleaded gasoline is around 20% (253.5714/1244.2577 = .2040). 

The final step in converting these exposures into futures equivalent positions is to take the dollar value of the index exposure to each 

commodity and determine how many lots of the underlying § 20.2 contract could be purchased at that day's price. In other words, on 

9/20/2011, 32.14% of the $230,267.8373 in value of the index is exposed to crude oil. Since the crude price settled at $80.0000/bbl on that 

day, and the crude contract is denominated in 1000 bbl, the futures equivalent position in crude oil would be equal to 0.9253 futures 

Data 

records

Commission 

Reporting 

Entity ID

Principal/Cou

nterparty 

Position 

Indicator

102S Swap 

Counterpart

y ID

Counterparty 

Name Reporting Day

Clearing 

Org 

Cleared 

Product ID

Commodity 

Code

Futures 

Equivalent 

Month and 

Year

Price 

Reference 

Month and 

Year

Cleared/ 

Uncleared 

Indicator

CFTC 

Clearing 

Org 

Identifier

Commodity 

Reference Price

Position Type 

Indicator

Execution 

Facility Long Swap Position Short Swap Position Put/Call Indicator

Swaption 

Date

Swaption 

Strike 

Price

NonStandard 

Swaption 

Indicator

Non-delta 

Adjusted 

Long 

Swaption 

Position

Non-delta 

Adjusted 

Short 

Swaption 

Position

Delta 

Adjusted 

Long 

Swaption 

Position

Delta 

Adjusted 

Short 

Swaption 

Position

Long Swap or 

Swaption 

Notional Value 

Position

Short Swap or 

Swaption Notional 

Value Position

Data 

record 113 SD5 Principal CP_ZZ SD5 2011-09-20 17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX IndexOrBasket 0.0000 1.6329 $0.00 $66,133.32

Data 

record 114 SD5 Principal CP_ZZ SD5 2011-09-20 17:00:00-05:00 NYMEX HO 2011-11 False HEATING OIL-NEW YORK-NYMEX IndexOrBasket 0.0000 0.2937 $0.00 $43,181.70

Data 

record 115 SD5 Principal CP_ZZ SD5 2011-09-20 17:00:00-05:00 NYMEX RB 2011-11 False GASOLINE-NEW YORK-NYMEX IndexOrBasket 0.0000 0.3147 $0.00 $46,927.05

Data 

record 116 SD5 Principal CP_ZZ SD5 2011-09-20 17:00:00-05:00 NYMEX CL 2011-11 False OIL-WTI-NYMEX IndexOrBasket 0.0000 0.9253 $0.00 $74,025.77

Data 

record 117 SD5 Counterparty CP_AB PENSION FUND

2011-09-20 

17:00:00-05:00 NYMEX NG 2011-11 False NATURAL GASNYMEX IndexOrBasket 1.6329 0.0000 $66,133.32 $0.00

Data 

record 118 SD5 Counterparty CP_AB PENSION FUND

2011-09-20 

17:00:00-05:00 NYMEX HO 2011-11 False HEATING OIL-NEW YORK-NYMEX IndexOrBasket 0.2937 0.0000 $43,181.70 $0.00

Data 

record 119 SD5 Counterparty CP_AB PENSION FUND

2011-09-20 

17:00:00-05:00 NYMEX RB 2011-11 False GASOLINE-NEW YORK-NYMEX IndexOrBasket 0.3147 0.0000 $46,927.05 $0.00

Data 

record 120 SD5 Counterparty CP_AB PENSION FUND

2011-09-20 

17:00:00-05:00 NYMEX CL 2011-11 False OIL-WTI-NYMEX IndexOrBasket 0.9253 0.0000 $74,025.77 $0.00
Page 52

equivalent November 2011 positions. Similarly, on 9/20/2011 the futures equivalent positions in November natural gas would be 1.6329 

contracts ((($230,267.8373 *0.2872)/$4.0500 per MMBTU)/10,000 MMBTU)). The futures equivalent position in November heating oil 

would be 0.2937 contracts ((($230,267.8373*0.1875)/$3.5000 per gallon/42,000 gallons)). The futures equivalent position in November 

unleaded gasoline would be 0.3147 contracts ((($230,267.8373*0.2038)/$3.5500 per gallon/42,000 gallons)).
Page 53

IV. Swap Transaction Examples

Swap A – Platts Heating Oil Swap

Swap Terms

Trade Date: 31 August, 2011

Effective Date: 01 September, 2011

Termination Date: 15 September, 2011

Commodity: NYMEX HO

Total Notional Quantity: 2,100,000 U.S. gallons

Notional Quantity per Calculation Period: 2,100,000 U.S. gallons

Calculation Period(s): One period from and including the Effective Date, to and including the Termination 

Date.

Payment Date(s): The third Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: SD1

Fixed Price USD 2.9000 per U.S. gallon

Floating Price Payer: Energy_Firm_1

Commodity Reference Price: HEATING OIL-NEW YORK (BARGE)-PLATTS U.S.

Specified Price: Product Price Assessment

Delivery Date(s): Spot Market Price

Price Source: Platts

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 54

Swap B – Platts Heating Oil Swap

Swap Terms

Trade Date: 31 August, 2011

Effective Date: 01 September, 2011

Termination Date: 15 September, 2011

Commodity: NYMEX HO

Total Notional Quantity: 2,100,000 U.S. gallons

Notional Quantity per Calculation Period: 2,100,000 U.S. gallons

Calculation Period(s): One period from and including the Effective Date, to and including the Termination 

Date.

Payment Date(s): The third Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: SD1

Fixed Price USD 3.0000 per U.S. gallon

Floating Price Payer: Energy_Firm_2

Commodity Reference Price: HEATING OIL-NEW YORK (BARGE)-PLATTS U.S.

Specified Price: Product Price Assessment

Delivery Date(s): Spot Market Price

Price Source: Platts

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 55

Swap C – Platts Heating Oil Swap

Swap Terms

Trade Date: 25 August, 2011

Effective Date: 01 September, 2011

Termination Date: 15 September, 2011

Commodity: NYMEX HO

Total Notional Quantity: 4,200,000 U.S. gallons

Notional Quantity per Calculation Period: 4,200,000 U.S. gallons

Calculation Period(s): One period from and including the Effective Date, to and including the Termination 

Date.

Payment Date(s): The third Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: SD1

Fixed Price USD 3.0000 per U.S. gallon

Floating Price Payer: Energy_Firm_2

Commodity Reference Price: HEATING OIL-NEW YORK (BARGE)-PLATTS U.S.

Specified Price: Product Price Assessment

Delivery Date(s): Spot Market Price

Price Source: Platts

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 56

Swap D – NYMEX Heating Oil Swap

Swap Terms

Trade Date: 31 August, 2011

Effective Date: 01 September, 2011

Termination Date: 30 November, 2011

Commodity: NYMEX HO

Total Notional Quantity: 44,100,000 U.S. gallons

Notional Quantity per Calculation Period: 14,700,000 U.S. gallons

Calculation Period(s): Three calendar-month periods from and including the Effective Date, to and 

including the Termination Date. 

Payment Date(s): The third Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: SD1

Fixed Price USD 3.0000 per U.S. gallon

Floating Price Payer: Energy_Firm_3

Commodity Reference Price: HEATING OIL-NEW YORK-NYMEX

Specified Price: Settlement Price

Delivery Date(s): The next-to-expire futures contract month corresponding to the pricing date for each 

Calculation Period(s).

Price Source: NYMEX

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 57

Swap E – Cleared Platts Heating Oil Swap

Swap Terms

Trade Date: 25 August, 2011

Effective Date: 01 September, 2011

Termination Date: 15 September, 2011

Commodity: NYMEX HO

Total Notional Quantity: 4,200,000 U.S. gallons

Notional Quantity per Calculation Period: 4,200,000 U.S. gallons

Calculation Period(s): One period from and including the Effective Date, to and including the Termination 

Date.

Payment Date(s): The third Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: SD1

Fixed Price USD 3.0000 per U.S. gallon

Floating Price Payer: Market [ABC_Clearing transacts as Agent to SD1]

Commodity Reference Price: HEATING OIL-NEW YORK (BARGE)-PLATTS U.S.

Specified Price: Product Price Assessment

Delivery Date(s): Spot Market Price

Price Source: Platts

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Cleared

Clearing Organization: CCO_ID_1

Execution: Centrally executed

Execution Facility: EX2
Page 58

Swap F – NYMEX Natural Gas Swap

Swap Terms

Trade Date: 31 August, 2011

Effective Date: 01 September, 2011

Termination Date: 31 October, 2011

Commodity: NYMEX NG

Total Notional Quantity: 2,500,000 MMBTU

Notional Quantity per Calculation Period: 1,250,000 MMBTU

Calculation Period(s): Two calendar-month periods from and including the Effective Date, to and including 

the Termination Date.

Payment Date(s): The fifth Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: SD1

Fixed Price USD 4.5000 per MMBTU

Floating Price Payer: XYZ_Firm

Commodity Reference Price: NATURAL GAS-NYMEX

Specified Price: Settlement Price

Delivery Date(s): The next-to-expire futures contract month corresponding to pricing date for each 

Calculation Period(s).

Price Source: NYMEX

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 59

Swap G – NYMEX Natural Gas Swap

Swap Terms

Trade Date: 31 August, 2011

Effective Date: 01 September, 2011

Termination Date: 30 September, 2011

Commodity: NYMEX NG

Total Notional Quantity: 750,000 MMBTU

Notional Quantity per Calculation Period: 750,000 MMBTU

Calculation Period(s): One period from and including the Effective Date, to and including the Termination 

Date.

Payment Date(s): The fifth Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: SD1

Fixed Price USD 4.5000 per MMBTU

Floating Price Payer: WVU_Firm

Commodity Reference Price: NATURAL GAS-NYMEX

Specified Price: Settlement Price

Delivery Date(s): The next-to-expire futures contract month corresponding to pricing date for each 

Calculation Period(s).

Price Source: NYMEX

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 60

Swap H – NYMEX Natural Gas Swap

Swap Terms

Trade Date: 31 August, 2011

Effective Date: 01 September, 2011

Termination Date: 30 September, 2011

Commodity: NYMEX NG

Total Notional Quantity: 1,000,000 MMBTU

Notional Quantity per Calculation Period: 1,000,000 MMBTU

Calculation Period(s): One period from and including the Effective Date, to and including the Termination 

Date.

Payment Date(s): The fifth Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: Energy_Firm_1

Fixed Price USD 4.5000 per MMBTU

Floating Price Payer: SD1

Commodity Reference Price: NATURAL GAS-NYMEX

Specified Price: Settlement Price

Delivery Date(s): The next-to-expire futures contract month corresponding to pricing date for each 

Calculation Period(s).

Price Source: NYMEX

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 61

Swap I – NYMEX Natural Gas Swap

Swap Terms

Trade Date: 01 August, 2011

Effective Date: 15 September, 2011

Termination Date: 30 September, 2011

Commodity: NYMEX NG

Total Notional Quantity: 1,000,000 MMBTU

Notional Quantity per Calculation Period: 1,000,000 MMBTU

Calculation Period(s): One period from and including the Effective Date, to and including the Termination 

Date.

Payment Date(s): The fifth Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: Energy_Firm_1

Floating Price Payer: SD1

Commodity Reference Price: NATURAL GAS-NYMEX

Specified Price: Settlement Price

Delivery Date(s): The next-to-expire futures contract month corresponding to pricing date for each 

Calculation Period(s).

Price Source: NYMEX

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Swaption Seller: SD1

Swaption Buyer: Energy_Firm_1

Expiration Date: 14 September, 2011

Premium: $80,000

Strike Price: USD 4.5000 per MMBTU

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 62

Swap J – Cleared CBOT Soybean Swap

Swap Terms

Trade Date: 31 August, 2011

Effective Date: 01 September, 2011

Termination Date: 30 November, 2011

Commodity: CBT S

Total Notional Quantity: 1,500,000 bushels

Notional Quantity per Calculation Period: 500,000 bushels

Calculation Period(s): Three calendar-month periods from and including the Effective Date, to and 

including the Termination Date.

Payment Date(s): The fifth Business Day following the last Pricing Date in the Calculation Period

Business Days: Chicago

Rounding: Accuracy to one-fourth (1/4) of one cent per bushel to be used in all calculations.

Fixed Price Payer: CP_10

Fixed Price USD 1400 cents per bushel

Floating Price Payer: SD1

Commodity Reference Price: SOYBEANS-CBOT

Specified Price: Settlement Price

Delivery Date(s): The next-to-expire futures contract month corresponding to each pricing date for 

each Calculation Period(s).

Price Source: CBOT

Pricing Date(s): Each Calendar Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Cleared

Clearing Organization: CCO_ID_2

Execution: Centrally executed

Execution Facility: EX2
Page 63

Swap K – Gas Daily Natural Gas Swap 

Swap Terms

Trade Date: 31 August, 2011

Effective Date: 01 September, 2011

Termination Date: 01 September, 2011

Commodity: NYMEX NG

Total Notional Quantity: 1,000,000 MMBTU

Notional Quantity per Calculation Period: 1,000,000 MMBTU

Calculation Period(s): One period from and including the Effective Date, to and including the Termination 

Date.

Payment Date(s): The third Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: Energy_Firm_2

Fixed Price USD 4.5000 per MMBTU

Floating Price Payer: SD1

Commodity Reference Price: NATURAL GAS-LOUISANA (HENRY HUB)-GAS DAILY

Specified Price: Product Price Assessment

Delivery Date(s): Spot Market Price

Price Source: Platts

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 64

Swap L – 1 Year EuroDollar Calendar Spread vs. 1 Year Gold Calendar Spread 

Swap Terms

Trade Date: 31 July, 2011

Effective Date: 27 September, 2011

Termination Date: 24 September, 2012

Commodity: CME ED, CMX GC

Total Notional Quantity: $100,000,000

Notional Quantity per Calculation Period: $100,000,000

Calculation Period(s): One period from and including the Effective Date, to and including the Termination Date.

Payment Date(s): Quarterly the Friday after the Quarterly Eurodollar Expiration

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Floating Price Payer (1): EF2

Floating Price (1): Notional Value multiplied by the difference between the EDZ12 – EDZ13 futures contracts

Floating Price Payer (2): BF1

Floating Price (2): Notional Value multiplied by the percent change between the GCZ13 and GCZ12 futures 

contracts. For example: NV * ((GCZ13 – GCZ12) / GCZ12)

Commodity Reference Price (1): GOLD-COMEX

Commodity Reference Price (2): EURODOLLARS-CME 

Specified Price: Settlement Price

Delivery Date(s): The last Monday of each Quarterly Eurodollar expiration.

Price Source(s): CME, CMX

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 65

Swap M – 1 Year NG Swaption Calendar Strip with a Strike Price @ $4.50 per MMBTU

Swap Terms

Trade Date: 31 July, 2011

Effective Date: 01 January, 2012

Termination Date: 31 December, 2012

Commodity: ICE QHH

Total Notional Quantity: 3,000,000 MMBTU (100 * 12 * 2500)

Notional Quantity per Calculation Period: 250,000 MMBTU (100 * 2500)

Calculation Period(s): Close of business 3 business days prior to the first calendar day of the contract series. (monthly)

Payment Date(s): Last Trading Day of the reference price future

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: EF1

Floating Price Payer: CO (Clearing Organization)

Commodity Reference Price: NATURAL GAS- NYMEX

Specified Price Settlement Price

Delivery Date The next-to-expire futures contract month corresponding to pricing date for each Calculation 

Period(s).

Price Source: NYMEX

Pricing Date: Daily 

Swaption Buyer SD1

Swaption Seller Clear_Org2

Options Expiration Date Last Trading Day of the reference price future.

Premium $48,000.00

Strike Price USD 4.50 per MMBTU

Execution/Clearing

Cleared/Uncleared: Cleared

Clearing Organization: Clear_Org2

Execution: Electronic

Execution Facility: SEF2
Page 66

Swap N – Commodity Index Swap with Heating Oil and Jet Fuel

Swap Terms

Trade Date: 25 August, 2011

Effective Date: 01 September, 2011

Termination Date: 15 September, 2011

Commodity (1): NYMEX HO

Commodity (2): Jet Fuel

Total Notional Quantity: 420,000 U.S. gallons heating oil, 100,000 U.S. gallons jet fuel

Notional Quantity per Calculation Period: 420,000 U.S. gallons heating oil, 100,000 U.S. gallons jet fuel

Calculation Period(s): One period from and including the Effective Date, to and including the Termination Date.

Payment Date(s): The third Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: AIRLINE1

Floating Price Payer: SD3

Commodity Reference Price (1): HEATING OIL-NEW YORK (BARGE)-PLATTS U.S.

Commodity Reference Price (2): JET FUEL-NEW YORK (BARGE)-PLATTS U.S.

Specified Price Product Price Assessment

Delivery Date Spot Market Price

Price Source: Platts

Pricing Date: The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None
Page 67

Swap O – ICE OTC Houston Ship Channel Basis

Swap Terms

Trade Date: 17 August, 2011 (for Oct 2011 HSX product)

Effective Date: 1 September 2011

Termination Date: 02 October, 2011

Commodity: NYMEX NG

Total Notional Quantity: 100,000 MMBTU

Notional Quantity per Calculation Period: 100,000 MMBTU

Calculation Period(s): One period from and including the Effective Date, to and including the Termination Date.

Payment Date(s): Variation margined daily with financial cash settlement two days after last trading day.

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: Market [CM1 transacts as Agent to Gas Company Inc]

Floating Price Payer: Gas Company Inc

Commodity Reference Price (1): A price in dollars per MMBTU dry equal to the monthly last settlement price for natural gas 

futures as made public by the New York Mercantile Exchange (NYMEX) for the month of 

production per ISDA commodity definitions

Commodity Reference Price (2): A price in dollars per MMBTU dry equal to the Index Price, as reported in Platts Inside 

FERC's Gas Market Report in the first of the month publication for each month, for the 

corresponding Hub and Determination Periods.

Execution/Clearing

Cleared/Uncleared: Cleared

Clearing Organization: ICE Clear Europe Limited

Execution: Centrally executed

Execution Facility: ICE
Page 68

Swap P – Diversified Commodity Index Swap 

Swap Terms

Trade Date: 31 August, 2011

Effective Date: 01 September, 2011

Termination Date: 30 September, 2011

Commodity: Diversified Commodity Index - DJUBENTR

Total Notional Quantity: $1,000 x Index Value

Notional Quantity per Calculation Period: $1,000 x Index Value

Calculation Period(s): One period from and including the Effective Date, to and including the Termination 

Date.

Payment Date(s): The third Business Day following the Pricing Date in the Calculation Period

Business Days: New York

Rounding: Accuracy to four (4) decimal places to be used in all calculations.

Fixed Price Payer: Pension Fund

Fixed Price $1,000 * Index Value of 225

Floating Price Payer: SD1

Commodity Reference Price: DJ-UBS CITREN

Specified Price: Product Price Assessment

Delivery Date(s): Lead Futures Contract(s)

Price Source: Dow Jones

Pricing Date(s): The last Commodity Business Day of the Calculation Period.

Execution/Clearing

Cleared/Uncleared: Uncleared

Clearing Organization: None

Execution: Executed bilaterally

Execution Facility: None

Break
Page 69

V. Technical Requirements

a. Formats

i. File Format for Part 20 Reporting

ii. Mapping of Part 20 to FpML and FIXML

b. Electronic Data Transmission Procedures

i. Formatting Data for Transmission

ii. Assembly and Compression

iii. Secure FTP Account Registration

iv. File Transmission

c. Technical Support

a. Formats

i. File Format for Part 20 Reporting

Compliant XML formats for reporting include the FpML Exposure Report described in FpML Working Draft 5.3(see 

http://www.fpml.org/ for more details) and the FIXML Position Report described in the FIX Protocol Global Technical Committee 

and Futures Industry Association, CFTC Large Trader Reporting for Commodities Swaps, Revision 1.5, January 14, 2012 (see 

http://www.fixprotocol.org/specifications/EP140 for more details).

ii. Mapping of Part 20 to FpML and FIXML

Please see Data Dictionary in Section II.

b. Electronic Data Transmission Procedures

The electronic formatted records will be transmitted to the Commission using Secure FTP.

i. Formatting Data for Transmission

The records will be consolidated into an XML formatted file following the FPML® Exposure Report or FIXML Position 

Report as described in the previous sections. The file name for submission should be created in the following manner:

SWAPEXP_[ORGTYP]_[REPTYP]_[IDENT]_[YYYYMMDD].[FORMAT][.“TEST”]

Where:

ORGTYP: 

Organization Type ORGTYP in File name

Clearing Member CM
Page 70

Clearing Organization CO

Swap Dealer SD

REPTYP:

Report Type REPTYP in 

Filename

Summary data by product in 

accordance with Regulation 20.3(c)

EOD

Paired Swap positions in accordance 

with regulation 20.3(b) for a 

Clearing Organization or regulation 

20.4(c) for a Swap Dealer or 

Clearing Member. This report type 

can include both cleared and 

uncleared positions.

PSP

Paired Swap positions in accordance 

with regulation 20.3(b) for a 

Clearing Organization or regulation 

20.4(c) for a Swap Dealer or 

Clearing Member. This report type 

would include cleared positions 

only.

PSPCL

Paired Swap positions in accordance 

with regulation 20.4(c) for a Swap 

Dealer or Clearing Member. This 

report type would include uncleared

positions only.

PSPUNCL

Please note, reporting entities may send their cleared and uncleared data in two distinct transmissions (files) provided they 

follow the Report Type naming convention above and use PSPCL and PSPUNCL or use OICL and OIUNCL as the REPTYP.
Page 71

IDENT:

This field is the 3-5 character identifier provided by the CFTC during the account registration process.

YYYYMMDD:

This field is the Year (4 digits), Month and day of the report date.

FORMAT:

Format of the File FORMAT in Filename

FpML reporting using the Exposure Record FpML

FIXML reporting using the Position Report fixml

TEST:

This field, if present (use the word “TEST”) tells the CFTC that this data is for testing purposes only, and will not be loaded 

into a production system. We will load the test data into our test systems, and can optionally provide feedback regarding the 

structure and content of the file at the reporting entities request.

As an example, if your firm’s identifier was ABC, and you are a Clearing Organization reporting paired swap positions in 

accordance with regulation 20.3 for September 22nd, 2011 and you are using the FpML record format, your file name would be 

“SWAPEXP_CO_PSP_ABC_20110922.fpml”. If you are the same Clearing Organization and reporting End of Day settlement 

prices data via FpML, your file name would be “SWAPEXP_CO_EOD_ABC_20110922.fpml”. 

Data providers can test their submissions by appending the string “TEST” to the end of their file names. Using the example above, 

if your firm’s identifier is “ABC”, and you are a Clearing Organization testing the reporting of paired swap positions for 

September 22nd, 2011 using FpML your file name would be “SWAPEXP_CO_PSP_ABC_20110922.fpml.TEST”. If you are the 

same Clearing Organization and testing the reporting of End of Day settlement prices data via FpML, your file name would be 

“SWAPEXP_CO_EOD_ABC_20110922.fpml.TEST”. Your firm can contact our Technical Support representative at 

SwapsTechSupport@cftc.gov to verify the results of test data you have submitted.

ii. Assembly and Compression

After assembling the data file, it should be compressed using the GZIP utility. The GZIP utility is freely available at 

http://www.gzip.org. Following the example provided above, the zipped files names would be 

SWAPEXP_CO_POS_ABC_20110922.gz and SWAPEXP_CO_EOD_ABC_20110922.gz. The file will then be transmitted 

to the CFTC using Secure FTP. The instructions for registering for a Secure FTP account follow.
Page 72

iii. Secure FTP Account Registration

The compressed files will be submitted to the CFTC via Secured File Transfer Protocol (SFTP). Many entities providing Part 

20 reporting already have FTP or SFTP accounts. Reporting entities with SFTP accounts can continue to use those accounts 

for Part 20 reporting. New reporters who do not already have an SFTP account, or reporters who only use non-secure FTP 

accounts, must request a Secure FTP account from the CFTC. The following steps describe the process for that request.

Registration Step 1:

The user will browse to the Account Creation Page on the Commission’s website 

(https://services.cftc.gov/CreateCFTCAccount/CreateLoginAccount.aspx). They will be presented with a CFTC Usage Agreement 

for review.

The user will be required to confirm that they have read the agreement and agree to abide by its terms by clicking the checkbox 

and pressing the “Agree” button.
Page 73
Page 74

Registration Step 2:

The user will be presented with the Account Creation page where they will be asked to supply:

• First Name – The first name of the user requesting the account

• Last Name – The last name (or surname) of the user requesting the account

• Company Name – The Company that will be supplying the data to the CFTC

• Email Address – The email address of the contact. The email address must be from the domain that will be submitting data; the 

Reporting Entities domain. Third party email domains (e.g., hotmail, yahoo, gmail) will not be accepted.

• Contact Telephone Number – The requestor’s phone number, in case CFTC will need to confirm the user via a phone call.

• Contact FAX Number (not required)

Once the user has submitted the data, the request will be passed to CFTC’s Office of Data and Technology for approval.
Page 75

Registration Step 3:

Once the account creation is approved, the user will be sent an email with a link to confirm the request. This email will include the threeletter Alpha Code that must be used for all data submissions made by this company to the CFTC.

Clicking the link (or posting the URL into a browser) will bring the user to the account confirmation screen where they will be asked to 

confirm the account creation request by typing in the three-letter Alpha Code supplied in the email.
Page 76

Once the user has confirmed with the Alpha Code, the page will tell them that their request has been submitted.

Registration Step 4:

The user will receive two follow-on emails from the CFTC. Each email will address guidelines for using this account. One email will 

contain the user’s new ID. It will also contain instructions on converting their FTP Account to a Secure FTP Account. All entities who 

are providing Part 20 reporting must use Secure FTP to transmit their data.
Page 77

Registration Step 5:

All reporting entities must exchange their Public Keys with the CFTC to activate their Secure FTP account. Please send your Public Key 

to FTPSupport@cftc.gov.

The second email will contain the user’s new password for the FTP account.

iv. File Transmission

Connect to the CFTC FTP site at traders.cftc.gov, and login using your account and password. At this point, the compressed file can 

be transferred using normal FTP commands. 

Upon file receipt, software at the CFTC will ingest the file through our firewall and begin processing of the data. 
Page 78

c. Technical Support

Please forward questions regarding format, content, and transmission of Part 20 data submissions to the CFTC at 

SwapsTechSupport@cftc.gov.
Page 79

VI. Appendix A

Sec. 20.2 Covered Contracts

Chicago Board of Trade (``CBOT'') Corn.

CBOT Ethanol.

CBOT Oats.

CBOT Rough Rice.

CBOT Soybean Meal.

CBOT Soybean Oil.

CBOT Soybeans.

CBOT Wheat.

Chicago Mercantile Exchange (``CME'') Butter.

CME Cheese.

CME Dry Whey.

CME Feeder Cattle.

CME Hardwood Pulp.

CME Lean Hogs.

CME Live Cattle.

CME Milk Class III.

CME Non Fat Dry Milk.

CME Random Length Lumber.

CME Softwood Pulp.

COMEX (``CMX'') Copper Grade 1.

CMX Gold.

CMX Silver.

ICE Futures U.S. (``ICUS'') Cocoa.

ICUS Coffee C.

ICUS Cotton No. 2.

ICUS Frozen Concentrated Orange Juice.

ICUS Sugar No. 11.

ICUS Sugar No. 16.

Kansas City Board of Trade (``KCBT'') Wheat.

Minneapolis Grain Exchange (``MGEX'') Wheat.

NYSELiffe (``NYL'') Gold, 100 Troy Oz.

NYL Silver, 5000 Troy Oz.

New York Mercantile Exchange (``NYMEX'') Cocoa.
Page 80

NYMEX Brent Financial.

NYMEX Central Appalachian Coal.

NYMEX Coffee.

NYMEX Cotton.

NYMEX Crude Oil, Light Sweet.

NYMEX Gasoline Blendstock (RBOB).

NYMEX Hot Rolled Coil Steel.

NYMEX Natural Gas.

NYMEX No. 2 Heating Oil, New York Harbor.

NYMEX Palladium.

NYMEX Platinum.

NYMEX Sugar No. 11.

NYMEX Uranium.

Diversified Commodity Index (See Sec. 20.11).

Underlying Commodity Codes:

Covered Contract Commodity Code

Chicago Board of Trade (‘‘CBOT’’) Corn. CBT C

CBOT Ethanol. CBT EH

CBOT Oats. CBT O

CBOT Rough Rice. CBT RR

CBOT Soybean Meal. CBT SM

CBOT Soybean Oil. CBT BO

CBOT Soybeans. CBT S

CBOT Wheat. CBT W

Chicago Mercantile Exchange (‘‘CME’’) Butter. CME CB

CME Cheese. CME CSC

CME Dry Whey. CME DY

CME Feeder Cattle. CME FC

CME Hardwood Pulp. CME HWP

CME Lean Hogs. CME LH

CME Live Cattle. CME LC

CME Milk Class III. CME DA

CME Non Fat Dry Milk. CME GNF
Page 81

CME Random Length Lumber. CME LB

CME Softwood Pulp. CME WP

COMEX (‘‘CMX’’) Copper Grade #1. CMX HG

CMX Gold. CMX GC

CMX Silver. CMX SI

ICE Futures U.S. (‘‘ICUS’’) Cocoa. ICUS CC

ICUS Coffee C. ICUS KC

ICUS Cotton No. 2. ICUS CT

ICUS Frozen Concentrated Orange Juice. ICUS OJ

ICUS Sugar No. 11. ICUS SB

ICUS Sugar No. 16. ICUS SF

Kansas City Board of Trade (‘‘KCBT’’)Wheat. KCBT KW

Minneapolis Grain Exchange (‘‘MGEX’’) Wheat. MGEX MWE

NYSELiffe (‘‘NYL’’) Gold, 100 Troy Oz. NYL ZG

NYL Silver, 5000 Troy Oz. NYL ZI

New York Mercantile Exchange (‘‘NYMEX’’) Cocoa. NYMEX CJ

NYMEX Brent Financial. NYMEX BZ

NYMEX Central Appalachian Coal. NYMEX QL

NYMEX Coffee. NYMEX KT

NYMEX Cotton. NYMEX TT

NYMEX Crude Oil, Light Sweet. NYMEX CL

NYMEX Gasoline Blendstock (RBOB). NYMEX RB

NYMEX Hot Rolled Coil Steel. NYMEX HR

NYMEX Natural Gas. NYMEX NG

NYMEX No. 2 Heating Oil, New York Harbor. NYMEX HO

NYMEX Palladium. NYMEX PA

NYMEX Platinum. NYMEX PL

NYMEX Sugar No. 11. NYMEX YO

NYMEX Uranium. NYMEX UX

Diversified Commodity Index (See § 20.11). Index

Other Other
Page 82

Appendix B: Reserved.

Appendix D: Layout for 102S Filing Submission*

Clearing

Member

Id 102SId 

Counterparty

Name Address ContactName ContactJobTitle ContactPhone ContactEmail

NatureOfSwaps

Activity

Reporting

Date

ZZZ 11111 ABC Corp 123 Main Street John Doe Vice President 5555551234 johndoe@example.com

Commercial 

Hedging

2011-12-

12

 * On November 18, 2013, the Commission adopted new rules that require, among other things, the electronic submission of a new Form 102S (the “New Form 102S”). 

See Commission, Ownership and Control Reports, Forms 102/102S, 40/40S, and 71; Final Rule, 78 FR 69178 (Nov. 18, 2013). On July 23, 2014, the Division issued noaction relief that provided additional time, until February 11, 2015, for reporting parties to comply with the requirement to submit the New Form 102S, and on February 

10, 2015 the Division extended this no-action relief until September 30, 2015.
Page 83

Appendix E: Part 20 Reporting Scenarios

CFTC Part 20 Reporting Scenarios

November 2011

1 Provided for illustrative purposes only.
Page 84

Table of Contents

Uncleared Swap Reporting:

Situation 1: Reports by Swap Dealers for Trades with Non-Reporting Counterparties

Situation 2: Reports by Swap Dealers for Trades with Other Swap Dealers and Non-Reporting 

Counterparties

Situation 3: Reports by Clearing Members for Trades with Non-Reporting Counterparties

Cleared Swap Reporting:

Situation 4: Reports by Clearing Members for Non-Swap Dealer Customers

Situation 5: Reports by Clearing Members for Swap Dealer and Non-Swap Dealer Customers

Situation 6: Reports by Clearing Members for Proprietary Trades

2
Page 85

Situation 1: Reports by Swap Dealers for Trades with Non-Reporting Counterparties

CP1

100 Long

100 Short

SD1

CP2

200 Short

200 Long

3

Situation 1 Facts

• CP1 and CP2 are legal counterparties to 

separate OTC transactions with SD1

• Each trade is uncleared

Situation 1 Reports1

By SD1:

• Report themselves as having a principal 

position of 300 Long

• Report CP1 as having a counterparty 

position of 100 Short

• Report CP2 as having a counterparty 

position of 200 Short

1 The data records that would be reported are similar to data records 1-3, 4-9, 12-17, 18-19, 26-27, 103-106, and 111-120 of 

the Guidebook for Part 20 Reports (“Guidebook”).
Page 86

Situation 2: Reports by Swap Dealers for Trades with Other Swap Dealers and NonReporting Counterparties

CP1

100 Long

100 Short

SD1

200 Short

200 Long

4

Situation 2 Facts

• CP1 and SD1 are legal counterparties to an 

OTC transaction

• SD1 and SD2 are legal counterparties to an 

OTC transaction

• Each trade is uncleared

Situation 2 Reports

By SD1:

• Report themselves as having a principal 

position of 100 Long and 200 Short

• Report CP1 as having a counterparty position 

of 100 Short

• Report SD2 as having a counterparty position 

of 200 Long

BY SD2:

• Report themselves as having a principal 

position of 200 Long

• Report SD1 as having a counterparty position 

of 200 Short

SD2
Page 87

Situation 3: Reports by Clearing Members for Trades with Non-Reporting 

Counterparties

CP1

100 Long

100 Short

CP2

200 Short

200 Long

5

Situation 3 Facts

• CP1 and CP2 are legal counterparties to 

separate OTC transactions with CM1

• Each trade is uncleared

Situation 3 Reports2

By CM1:

• Report themselves as having a principal 

position of 300 Long

• Report CP1 as having a counterparty 

position of 100 Short

• Report CP2 as having a counterparty 

position of 200 Short

CM1

2 See, e.g., data records 71-78 of the Guidebook.
Page 88

Situation 4: Reports by Clearing Members for Non-Swap Dealer Customers

6

Situation 4 Facts

• CP1 is a customer of CM1 and CP2 is a customer of 

CM2

• CM1 and CM2 take no proprietary positions

• CP1 and CP2 trade through central execution, and do 

not know each other

Situation 4 Reports3

By CM1:

• Report an “agent”4 data record showing a 100 Short 

exposure

• Report CP1 as having a customer position of 100 Long

By CM2:

• Report an “agent” data record showing a 100 Long 

exposure

• Report CP2 as having a customer position of 100 Short

SEF/

DCO

CM1 CM2

CP1 CP2

100 Long 100 Short

100 Short 100 Long

3 See, e.g., data records 53-70 and 107-110 of the Guidebook.

4 “Agent” and “customer” data records are only to be reported by a clearing member when the paired swaps do not result in 

proprietary positions for the clearing member.
Page 89

Situation 5: Reports by Clearing Members for Swap Dealer and Non-Swap Dealer 

Customers

7

Situation 5 Facts

• CP1, CP2, and SD1 are customers of CM1

• CM1 takes no proprietary positions

• CP1 ,CP2, and SD1 trade through central execution, 

and do not know each other

Situation 5 Reports5

By CM1:

• Report an “agent” data record showing a 200 Short 

exposure and a 100 Long exposure

• Report CP1 as having a customer position of 100 Long

• Report CP2 as having a customer position of 100 Short

• Report SD1 as having a customer position of 100 Long

By SD1:

• Report themselves as having a principal position of 

100 Long 

• Report CM1 as having a counterparty position of 100 

Short

SEF/

DCO

CM1

CP1 CP2

100 Long

100 Short

200 Short 100 Long

SD1

100 Long

5 See, e.g., data records 10-11, 20-25, 53-70, 79-102, and 107-110 of the Guidebook.
Page 90

Situation 6: Reports by Clearing Members for Proprietary Trades

8

Situation 6 Facts

• CM1 makes proprietary trades at a central execution venue

• The identity of the entity matched against CM1’s trades is 

unknown

Situation 6 Reports

By CM1:

• Report themselves as having a principal position of 100 Long

• CM1 does not report any counterparty positions

SEF/

DCO

CM1

100 Long

100 Short