CFTC

CFTC Swap Data Reporting is the United States’ primary framework for post-trade transparency and regulatory oversight of over-the-counter (OTC) derivatives markets, established under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The regime was enacted in direct response to the 2008 financial crisis, and mandates the reporting of all swap transactions to a registered Swap Data Repository (SDR) to give regulators a comprehensive, real-time view of derivatives market activity and systemic risk exposure.

Under CFTC regulations — principally Part 45 (swap data recordkeeping and reporting) and Part 43 (real-time public reporting) — the reporting obligation falls on the designated reporting counterparty, determined by a strict hierarchy: Swap Dealers (SDs) report first, followed by Major Swap Participants (MSPs), then U.S. persons. Reports must be submitted to a registered SDR as of the same day of execution for electronically executed swaps, and no later than the next business day for off-facility swaps. The framework covers all five asset classes: interest rate, credit, foreign exchange, equity, and commodity derivatives.

Key Obligations

• Single-sided reporting with a defined hierarchy — only the reporting counterparty is obligated to submit, determined by SD > MSP > U.S. person precedence under § 45.8; the non-reporting counterparty retains verification obligation
• Unique Transaction Identifier (UTI) — mandatory for all swaps executed on or after 5 December 2022; Unique Swap Identifiers (USIs) are no longer accepted for new transactions
• Unique Product Identifier (UPI) — issued by the Derivatives Service Bureau (DSB), mandatory across interest rate, credit, FX, and equity asset classes since January 2024, with commodity asset classes to follow
• Legal Entity Identifier (LEI) — all reporting and non-reporting counterparties must hold a valid, renewed LEI
• Daily margin and collateral reporting — Swap Dealers and Major Swap Participants must report margin and collateral data each business day under § 45.4(c)(2)
• Lifecycle event reporting — any modification, novation, compression, termination, or partial termination must be reported with the correct action type and event type combination on the day of occurrence
• Data verification obligations — under § 45.14, reporting counterparties must regularly verify the completeness and accuracy of all open swap data held at the SDR, and correct any errors as soon as technologically practicable following discovery

CFTC Rewrite

The CFTC Rewrite, which went live on 5 December 2022, was the most comprehensive overhaul of the US swap reporting framework since the original Dodd-Frank rules came into force in 2013. The Rewrite introduced a substantially expanded set of reportable data fields aligned with the CPMI-IOSCO Critical Data Elements (CDE) harmonisation standard, replaced the USI with the globally consistent UTI, and introduced entirely new obligations under Part 49 around data verification, error correction, and self-reporting of notification forms to the CFTC when timely corrections cannot be made. Collateral and margin reporting was significantly enhanced to give the Commission improved systemic risk monitoring capabilities.

A supplemental historical data upgrade obligation required all open swaps reported prior to 5 December 2022 to be re-submitted in the new format by 5 June 2023.

Point Nine’s platform is fully aligned with the post-Rewrite CFTC requirements, providing automated field mapping to the CDE standard, pre-submission validation against Part 43 and Part 45 rules, and direct connectivity to all major registered SDRs.