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CFTC Rewrite: Tackling Your Trade Reporting Data Quality Challenges

By DTCC Connection Staff | March 21, 2022

It’s official: the Commodity Futures Trading Commission (CFTC) has delayed its trade reporting rules rewrite to December 5, 2022. Despite the delay, DTCC encourages clients to fast-track their preparations for the CFTC rewrite or any of the other upcoming derivatives trade reporting rule revisions.

Related: DTCC's Chris Childs on Bracing for Trade Reporting Changes

In a recent virtual event, DTCC’s panel of trade reporting experts, Carolyn Kostelny, Business Management, DTCC Consulting Services, Mark Steadman, Executive Director and Head of DTCC Report Hub®, and Val Wotton, Managing Director of Product Development and Strategy for DTCC’s Repository and Derivatives Services (RDS) discussed and how DTCC Report Hub’s and DTCC Consulting Services can help clients tackle their CFTC reporting data quality challenges.

If you missed the live webinar you can click here to register to watch the replay. An overview of the conversation is below.

  • Two-Step Implementation: The CFTC rewrite will now be implemented in two parts. Phase 1 focuses on the technical message specification which adopts many of CPMI-IOSCO’s Critical Data Elements (CDE) and the Unique Trade Identifier (UTI), and introduces new Validations, Action Types, and the reporting of Collateral. Phase 2 will now include the implementation of the Unique Product Identifier (UPI) and ISO 20022 XML, currently expected to go into effect in late 2023.
  • Updated and New Requirements: Other significant changes of the CFTC rewrite include updated reconciliation requirements and rules on the processing of corrections, and the introduction of a transition process where firms are required to upgrade historical live records.
  • Navigating the Shifting Landscape: Updating internal operations and technology systems to be able to source and report trade data in compliance with the CFTC’s revised rules is a taxing undertaking on its own, and for many, these challenges are compounded by the upcoming refits and rewrites across other global derivatives reporting regimes. Adding to the complexities of adjusting to revised reporting rules, we’re also operating in a climate of enhanced regulatory scrutiny. In fact, since 2019 the CFTC has fined firms nearly $20 million for failure to comply with their reporting rules*.
  • A Next-Gen Solution: When it comes to their reporting infrastructure, controls and processes, clients should consider finding a service that delivers the greatest value while addressing their trade reporting challenges. DTCC’s Report Hub is a highly efficient pre and post trade reporting solution that can help clients manage the complexities of meeting multiple regulatory mandates across 14 jurisdictions. With comprehensive jurisdictional and regulation coverage, the service can help firms mitigate compliance risks, enhance operational efficiencies, and drive down costs.
  • Our Expertise, Your Organization: DTCC Consulting Services is uniquely positioned to provide clients with consulting services that tap into the breadth and depth of our experience to help you transform your trade reporting operations, increase efficiencies, reduce risks, and drive down costs.

The changes introduced by the CFTC rewrite are not insignificant, but DTCC’s Report Hub and Consulting Services clients can help fast-track your readiness. Reach out to get started today.

*Data derived from the CFTC website

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