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July 17, 2019

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CFTC Announces Review of Swaps Reporting Regulations

On July 10, the Commodity Futures Trading Commission’s Division of Market Oversight (Division) issued Staff Letter 17-33 (Staff Letter), which announced the launch of a comprehensive review of swap data reporting requirements. The review will focus on existing regulations with the goal of (1) ensuring the CFTC receives accurate, complete and high-quality data regarding swap transactions, (2) streamlining data reporting, (3) reducing the number of messages that must be reported, and (4) right-sizing the number of data elements reported to meet the CFTC’s prior use cases for swap data. In addition to the Staff Letter, the Division also released the Roadmap to Achieve High Quality Swaps Data (Roadmap), which outlines the Division’s plan for improving swap data reporting. Upon the completion of its review, the CFTC expects to adopt final rules and have full industry implementation by the end of 2019.

To solicit industry feedback regarding the plan outlined in the Roadmap, the CFTC has opened a 40-day comment period, which will end on August 21.

Staff Letter 17-33 is available here.

The Roadmap to Achieve High Quality Swaps Data is available here.

©2019 Katten Muchin Rosenman LLP


About this Author

Kevin M. Foley, Finance Lawyer, Katten Llaw Firm

Kevin M. Foley has extensive experience in commodities law and advises a wide range of clients, both in the United States and abroad, on compliance with the Commodity Exchange Act and the rules of the Commodity Futures Trading Commission (CFTC) affecting traditional exchange-traded products, as well as the over-the-counter markets involving swaps and other derivative instruments. His clients include futures commission merchants, derivatives clearing organizations, designated contract markets, foreign boards of trade and an industry trade association.


Stanley V. Polit, Katten Muchin, Financial Services lawyer, Corporate Regulatory Matters Attorney

Stanley Polit concentrates his practice in transactional, corporate and regulatory aspects of financial services matters. Stan is able to provide legal services to a wide variety of clients including proprietary trading firms, hedge funds, broker-dealers, registered investment advisers, commodity trading advisers, financial institutions and general corporate clients.

Prior to joining Katten, Stan served as a council member for a national crisis management firm, where he specialized in crisis communication and merged media strategies. He has lectured extensively and conducted trainings related to these topics at numerous national and international conferences, including the National Communication Association's National Convention, the International Crisis and Risk Communication Conference and the Disaster Recovery Journal's World Business Continuity Conference.