CFTC

TAC Meeting

September 12, 2013

Update on Swaps Data Reporting
Commodity Futures Trading Commission

What are the Commission’s Objectives

• Harmonization

– SDRs must standardize the data elements and content in order for the 

CFTC to aggregate data across SDRs 

• Quality

– SDRs must validate and normalize data

• Accessibility

– SDRs must provide direct electronic access for CFTC staff to search, query, 

filter, sort and export swaps data

• Analytics

– SDRs must develop reports and analyses of SDR operations, data quality, 

and industry data points across asset classes
Commodity Futures Trading Commission

Harmonization (Standardization)

• Phase 1 Process and Progress

– Staff is working with each SDR separately on SDR specific issues

– Staff is also working with the SDRs in a cross-SDR team effort

– Efforts are focused on data elements that may include PET data from 

Part 45 or Part 43, as well as SDR information as defined in Part 49

– Efforts are focused on harmonizing data already existing in the SDRs, not 

on requiring new data from submitters

– Efforts are focused on CDS asset class first to work in a manageable 

way, then will apply to other asset classes where appropriate 

– Effort does not focus on delivery method or location of data but 

agreement on consistent data content is key

– Effort currently is not an FIXML or FpML discussion

– SDRs will develop an Action Plan by asset class and data element 3
Commodity Futures Trading Commission

Harmonization (Standardization)

• Phase 2 Effort

– Additional selection of core data elements

– Continued focus on CDS asset class

• Key Considerations of Harmonization Effort

– Impact on entities (data submitters) reporting to SDRs

– Prioritizing timing of implementation release cycles to deliver new portal 

functionality

– Impact of global data standards

– Potential data uses by CFTC

• Future Phases

– Focus of Phase 3 is to add more core data elements for CDS`

– Focus of Phase 4 will shift to different asset classes

– Additional data elements will be considered as needed

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Commodity Futures Trading Commission

Process Going Forward

• CFTC will have an ongoing dialogue to work through 

regulatory requirements for SDRs and phasing of 

implementation

– CFTC will be taking the best capabilities of each SDR and making them 

requirements for others to achieve the highest common denominator of 

standardization and capability

– This will mainly relate to functional requirements of the SDR, not how 

requirements are technically implemented

– SDRs will provide action plans by phase and by asset class to 

document how they will implement harmonization

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Commodity Futures Trading Commission

SDR Progress Report

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• Harmonization:

– What are the aggregation capabilities?

• Data Quality: 

– What is being done to ensure data quality?

• Accessibility: 

– What regulatory portal modifications are being implemented?

• Analytics: 

– What are the reporting capabilities?
Commodity Futures Trading Commission

SDR Progress– April to Present

• Issues Identified

– At April TAC meeting, Commissioners and Staff identified issues with 

aggregating swap data amongst CME, DDR & ICE (SDR file formats & 

data content were not standardized)

– CFTC analysis of CICI registration illustrated the need for market 

participants to register for CICIs (cross-border guidance & end-user 

adoption)

• Key Outcomes 

– A series of meetings & calls were held by CFTC staff with SDRs (strawman of Phase 1 data elements for credit default swaps asset class)

– CFTC Office of Data & Technology requested SDRs to provide CICI 

reports (SDRs analyzed submitted swap data for CICI submission & 

encouraged CICI registration)

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Commodity Futures Trading Commission

Joint-SDR Harmonization Initiative– Phase I

• Process and Progress

– CME, DDR & ICE are uniformly working to provide standardized, 

normalized data (collectively “harmonized data”) to the CFTC

– The SDRs have collaboratively completed analysis and proposed 

recommendations for Phase I scope (data elements and definitions)

– The SDRs have accommodated CFTC requests to include data elements 

that extend beyond P45 data where those elements can be derived from 

existing SDR data

• Key Outcomes 

– Implementation of the harmonization effort will focus on modifying the 

data output to the CFTC, reducing impact on inbound submissions

– The results of the harmonization effort will be reflected both in the reports 

and the portal access provided by SDRs to the Commission

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Commodity Futures Trading Commission

The Next Phases and Challenges

• Harmonization – Future Phases

– Beginning phases include those fields that require a change in data presentation and/or 

can be derived from the data currently supplied to an SDR.

– Multi-phased approach across asset classes (commencing with CDS)

– The inclusion of fields that would require reporting parties to provide additional 

information that they are currently not obligated to report is being discussed.

• Multiple Resource Demands

– Improving data quality and making further strides in harmonization needs to be 

balanced against implementation of upcoming regulatory requirements. 

• Swap Execution Facilities (SEFs)

– The shift in the reporting obligation from the counterparties to a swap transaction to 

SEFs will effect data quality.

• The degree of industry preparedness on the SEF Compliance Date will determine 

whether data quality increases or decreases (i.e., inability of counterparties to suppress 

the reporting of transactions traded on a SEF will result in double reporting).

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