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July 09, 2020

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CFTC Requests Comment on Swap Data Reporting Rules - Commodity Futures Trading Commission

On March 19, the Commodity Futures Trading Commission approved for publication in the Federal Register a request for public comment on swap data reporting requirements under Part 45 of the CFTC’s regulations. The request was developed by a CFTC interdivisional working group that was charged with reviewing the reporting rules and making recommendations for resolving reporting challenges. The request seeks comment on confirmation data reporting, continuation data reporting, reporting transactions and workflows not explicitly addressed in swap data reporting rules, monitoring the primary economic terms of a swap, reporting of cleared swaps, other swap data repository (SDR) and counterparty obligations, swap dealer and major swap participant oversight, risk monitoring and surveillance, and swap data ownership and transfer across SDRs. Although the CFTC did not specifically request comments regarding the requirements imposed by Part 43 of its regulations (real-time public reporting of swap transaction data) or Part 46 (recordkeeping and reporting for pre-enactment and transition swaps), it did invite comments on other “challenges” associated with the reporting of swap transaction data.

Comments are due 60 days after publication in the Federal Register.

©2020 Katten Muchin Rosenman LLPNational Law Review, Volume IV, Number 80

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About this Author

Henry Bregstein, Katten Muchin Law Firm, Financial Institutions Legal Specialist
Partner

Henry Bregstein is the global co-chair of the firm’s Financial Services practice and a member of the firm’s Executive Committee and Board of Directors. In his role as partner in the Financial Services practice, he advises banks, domestic and offshore hedge funds, private equity funds, life insurance companies, family offices, sovereign wealth funds, investment advisers and broker-dealers on regulatory, securities, tax, finance, licensing, corporate and other legal matters.

Henry provides guidance on fund formation and regulatory compliance and advice related to...

212-940-6615
Wendy E. Cohen, Financial Services Lawyer, Katten Muchin Law firm
Partner

Wendy E. Cohen represents investment managers and other sponsors of domestic and offshore securities and commodities hedge funds, funds of funds and other public and private pooled investment vehicles, as well as their service providers, including their managers, brokers, financial intermediaries and other financial institutions, and investment professionals. She provides advice on all corporate and related matters facing investment funds, including structure and organization, ongoing operations, restructuring and dissolution.

Having practiced for...

212-940-3846
Guy Dempsey Jr., Bank Regulations Legal Specialist, Katten Muchin
Partner

Guy C. Dempsey Jr. concentrates his practice on derivatives and structured products and on bank regulation. He advises clients on derivatives transactions of all types across all asset classes, as well as on the corporate governance, regulatory, collateral, compliance, insolvency and litigation issues associated with such products.

Much of Guy’s work involves helping bank and non-bank clients analyze the details and impact of the Dodd-Frank Act. He maintains deep knowledge of the banking laws and regulations relating to capital markets activities....

212-940-8593
Kevin M. Foley, Finance Lawyer, Katten Llaw Firm
Partner

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.

...

312-902-5372