GMAC TECHNICAL ISSUES SUBCOMMITTEE RECOMMENDATION

Improve Trade Reporting for Market Oversight

Improving Data Sharing and Systemic Risk Analysis

Issue: Global Rewrites/Refits are based on implementation of CDE, UPI and

UTI to enable data amalgamation to facilitate regulatory data usage

across jurisdictions.  However, there are non‐data related

impediments that could prevent data sharing thus delivering minimal

value from these significant projects.

Recommendation: In the short‐term the CFTC should facilitate discussions with key

regulators (market and prudential) on the desire to share data

elements and agree upon the MOUs needed to allow such activity,

starting with US and then prioritize other G20 regulators where there

is significant overlap.   

Not all reported data needs to be shared to start systemic risk

analysis and by working with the global Regulatory Oversight

Committee1 (ROC) regulators could identify the subset of CDE

required for this purpose.  Provided clear and consistent validation

requirements for that data set are adopted globally, data sharing

could yield valuable information for effective regulatory oversight.

(Note: If this is an accepted recommendation the Technical Issues

Sub‐committee could draft an initial proposal on this subset of data.)

The CFTC should work through an existing regulatory body, like

IOSCO, to create working groups comprising regulators, trade

associations and industry participants to identify, assess and address

data sharing issues in three areas:  

 Governance, Legal and Regulatory

 Streamlining access to a harmonized data set

 Non‐data jurisdictional differences that may prevent effective

data amalgamation

Background,  

Supporting

Arguments or

Examples & Data (if

any)

1. Governance

Proper governance is quite possibly the single most important part of

a complex data sharing ecosystem (multi‐jurisdictional, multi data

stores, multi technology) to enable an effectively functioning

amalgamation and analysis of data. Amongst others, this may include

data sharing agreements and a global regulatory body that oversees

the technologies used by market and prudential regulators to share

                                                            

1 https://www.leiroc.org/
and amalgamate data. A key output from the proposed work will be

the identification of governance issues and recommended solutions.

2. Streamlining access to a harmonized data set

A prerequisite to enhance how to analyze global data sets, is

agreement on the subset of CDE fields which are most relevant to

this purpose.  The LEI, UTI, UPI and other core data fields can be

valuable tools to assess counterparty, risk, notional, and underlier

exposures, however.  Market participants assess risk in their firms

every day and so are well‐positioned to partner with regulators to

recommend ways and methods to best leverage the available data.  

3. Non‐data jurisdictional differences preventing effective data

amalgamation

A group focused on the identification and resolution of

implementation issues could complement the work of the Regulatory

Oversight Committee (ROC) to remove technical barriers to data

amalgamation.  Examples are:

 An FX swap is considered a single trade in the EU for the

purposes of reporting, whereas under the CFTC an FX swap is

reported as two transactions for each leg, linked with a

package identifier;

 Some jurisdictions regard the latest data submission as the

gold‐source, whereas others regard the submission with the

most recent event type as the current source of truth; and,

 Amending a counterparty to a reported trade can be done via

a cancel/correct with a new UTI (ESMA) or a modification

using the existing UTI (CFTC).

These examples will result in either the same trades reported to

different jurisdictions with different UTIs or trades with the same UTI

but with different current values of data.