Roadmap to Achieve 

 High Quality Swaps Data 

July 10, 2017 

CFTC

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Commodity Futures Trading Commission 

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Joint Statement of Acting Chairman Christopher Giancarlo

and Commissioner Sharon Y. Bowen 

The CFTC is committed to fully implementing the standards for OTC derivatives markets agreed at the 2009 

Pittsburgh G-20 summit and codified in the Dodd-Frank Act. This continued effort includes post-trade transparency 

for regulators into the swaps market. Recently, we directed the Division of Market Oversight (DMO) to take stock of 

our progress to date and assess required future steps to achieve the goal of high quality swaps data for post-trade 

transparency. This roadmap is a reflection of DMO’s effort. It maps out steps forward to ensure we have complete, 

accurate, and high-quality data to fulfill our statutory responsibilities. This roadmap also communicates DMO’s plan 

to the marketplace so that it can plan and budget for the upcoming amendments. 

We aim to complete this process with full industry implementation by the end of 2019. This timeline allows the 

Commission to conduct rulemakings in regular order, including consultation with market participants and sufficient 

time for the public comment process. This timeline also allows us to leverage the international data harmonization 

processes. Regulators, through CPMI, IOSCO, and the FSB, will be providing guidance on the harmonization of key 

identifiers and technical specifications for critical data elements. Further, market participants and SDRs involved in 

swaps reporting must have time to build and test required system changes so this plan provides a reasonable 

implementation period. 

We look forward to working with all stakeholders – including market participants, SDRs, and our fellow regulators – to 

ensure that we have the optimal data and swap reporting regime to identify and address potential problems in the 

global systemically important derivatives market. As part of this effort, we have asked DMO to accept comments on 

this roadmap for the next 40 days. 
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Commodity Futures Trading Commission 

DMO Goals in Review of Reporting Regulations 

• To ensure the CFTC receives accurate, complete, and high quality 

data on swaps transactions for its regulatory oversight role 

• To streamline reporting, reduce messages that must be reported, 

and right-size the number of data elements that are reported to 

meet the priority use-cases of the agency 

• Evaluate Parts 43, 45, and 49 of Commission Regulations to 

identify provisions that need updating or changing to meet these 

goals and clarify obligations for reporting counterparties and SDRs 
Commodity Futures Trading Commission 

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DMO Roadmap to Complete Review 

Project

Review of SDR 

Operations 

(Tranche 1) 

Harmonizing Data

Elements 

Review of Reporting 

Workflows 

(Tranche 2) 

Anticipated Time Frames 

NPRM and Draft 

Validations 

Q4 2017 

CPMI-IOSCO 

Batch 3 Report 

Q1 2018 

NPRM and Draft 

Data Elements 

Q1/Q2 2018 

Final Rule 

Q2 2018 

Compliance 

Date 

No Later Than 

Dec 2019 

Final Rule

Q4 2018

Compliance 

Date 

No Later Than 

Dec 2019 

National Authorities 

Implement Elements 

Post- Q1 2018 
Commodity Futures Trading Commission 

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Tranche 1: SDR Operations Review

SDR Validations

• Leverage existing SDR validation processes to improve 

consistency and completeness of data reporting 

• Work with SDRs to set up processes for rejecting swap data 

reports with missing or invalid data 

• Identify initial set of minimum validations, including blank/not 

blank validations and some allowable values and format 

validations where appropriate 
Commodity Futures Trading Commission 

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Tranche 1: SDR Operations Review

Ensure Counterparties Confirm Accuracy of SDR Data

• Identify most efficient and effective solution for swap 

counterparty(ies) to confirm the accuracy and completeness of 

data held in an SDR 

• Consider which counterparty(ies) must perform 

reconciliations 

• Consider frequency of reconciliation against the 

counterparty’s internal book

• Consider whether to require reconciliation of position data 

or full audit trail of each swap 
Commodity Futures Trading Commission 

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Tranche 2: Reporting Workflows 

Streamline Workflows

• Explore whether to combine PET and Confirmation data into 

single, clearly defined, and electronically reportable set of data 

elements 

• Work to remove uncertainty as to what must be reported and how 

• Eliminate multiple reporting streams and unnecessary messages 
Commodity Futures Trading Commission 

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Tranche 2: Reporting Workflows

Focus on Key Data Fields

• Work to harmonize data fields with foreign regulators, 

building on CPMI-IOSCO process and Dec 2015 CFTC RFC 

• Look to reduce the number of fields currently reported 

• Focus on minimum number of fields that allow CFTC to 

perform its oversight functions, rather than capturing 

every data point on a swap 

• May expand to cover margin movements and discrete data 

points relating to risk and positions, with an eye to 

consistency with how this is reported under ESMA rules 

• Recordkeeping requirements would continue for all terms 

of a swap, even those not required to be reported 
Commodity Futures Trading Commission 

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Tranche 2: Reporting Workflows

Technical Specification

• Once CPMI-IOSCO harmonization efforts have sufficiently 

progressed, DMO will propose detailed technical specifications 

• Would include definitions, form and manner specifications, 

mapping to existing data languages (FpML and FIX), and 

allowable values where appropriate 

• Will seek to match foreign regulators as closely as possible, 

although some elements may be different depending on 

Commission’s needs

• Update specifications for SDR validations to cover full suite of 

required data elements and include remaining allowable values 

and format validations 
Commodity Futures Trading Commission 

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Tranche 2: Reporting Workflows

Re-evaluate Reporting Deadlines under Part 45 

• Explore alignment of CFTC with the SEC and ESMA, including 

potential move to T+1 reporting 

• Explore whether changing deadlines will improve data accuracy 

by building upon existing market practice of trade confirmations 

• Find ways to leverage existing confirmation processes to aid in 

reporting, where appropriate 
Commodity Futures Trading Commission 

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Tranche 2: Reporting Workflows 

Increase the Utility of the Real-Time Public Tape

• Evaluate real-time reporting regulations in light of goals of 

liquidity, transparency, and price discovery in the swaps market

• Address ongoing issues of reporting packages, prime brokerage, 

allocations, risk mitigation services/compressions, EFRPs, and 

post-priced swaps by clarifying obligations and identifying those 

distinct types of transactions to increase the utility of the realtime public tape
Commodity Futures Trading Commission 

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Target timeframes for review 

DMO hopes to present the Commission with two sets of 

proposals over the next year: 

• Tranche 1: SDR operations– NPRM Q4 2017 

• Tranche 2: Reporting workflows – NPRM late Q1 / early Q2 

2018 

• Consider compliance schedule for implementing both 

tranches that balances efficiency, timeliness, burden, and 

improved reporting