大约十年前，美国政府宣布了.S.’s Commodity Futures Trading Commission (CFTC) led the global regulatory community as the first jurisdiction to implement requirements for the reporting of over-the-counter (OTC) derivatives to a registered trade repository under the Dodd-Frank Act. 在我们即将迎来贸易报道十周年之际, 美国商品期货交易委员会(CFTC)将再次带头冲锋，这是合适的, this time with the upcoming launch of their rules rewrite as the global regulatory community works to revamp reporting requirements with a renewed focus on data harmonization.
相关:应对CFTC报告数据质量挑战
Up until now the derivatives industry has seen the roll-out of diverging requirements as each global regulatory regime set out their own take on derivatives reporting rules. 在过去的几年里, 存, as the provider of multiple registered trade repositories providing reporting services across 12 jurisdictions through our 全球贸易仓库服务(GTR), 一直在敦促全球监管界, 与主要行业vnsr威尼斯城官网登入和标准制定机构合作, 以获得更统一的数据要求. Standardization of regulatory data is the foundation necessary to increase transparency and mitigate systemic risk inherent in the global derivatives markets – a mandate that was set forth by the G20 in their historic Pittsburgh summit after the 2008 financial crisis. 现在, 在我们发布贸易报告的十年之际, a wave of regulatory rule rewrites and refits is set to address the lack of harmonization in reporting requirements across jurisdictions and put us back on the path towards global data harmonization.
为冲击做准备
CFTC将于12月5日开始实施第一阶段的修改, 2022, 重点关注新的和更新的数据字段, 推动提交更加标准化的贸易数据. The CFTC’s updated requirements adopt 71% (78 out of 110) of the Committee on Payments and Market Infrastructures and the 国际 Organization of Securities Commissions (CPMI-IOSCO) Critical Data Elements (CDE) and introduces the reporting of Collateral Valuations and a Unique Transaction Identifier (UTI).
Other important changes include new and updated validation rules as well as revised reconciliation requirements – including the need for reporting parties to correct their reports within seven business days should any errors or omissions be identified, 如果他们不能这样做, to notify the CFTC’s Division of Market Oversight and include a remediation plan.
All of these changes are significant, and the impact will be felt across the derivatives ecosystem. Adjustments will need to be made across the board – from reporting parties and swap data repositories (SDRs), 如存数据存储库(U.S.)有限责任公司, 与交易有关的其他各方, 包括掉期执行设施和结算所. 鉴于存在资本市场上的独特作用, we understand the complexity of data quality and the importance of reporting this data correctly, 并花了数百个小时与监管机构会面, 行业vnsr威尼斯城官网登入, 标准组织, 客户和其他市场参与者为CFTC重写做准备.
行业合作
在存，我们相信合作有利于整个行业. 通过与其他特别提款权和行业vnsr威尼斯城官网登入的工作组, 包括国际掉期和衍生工具vnsr威尼斯城官网登入(ISDA), 我们分析了CFTC提出的每一项要求, providing feedback and requesting revisions and then relaying that information to industry partners and our own working groups.
作为SDR, we have spent nearly two years supporting DDR’s clients as they prepare for the changes to CFTC reporting. 考虑到北美报道的性质, 我们将在加拿大(所有13个监管机构)和美国实施所有适用的变更.S. 美国证券交易委员会(SEC)同时报告. We believe this approach will best serve our clients by consolidating the changes they need to make to their trade reporting infrastructures. 加拿大已经提议对其法规进行修改，这些修改将在稍后完成, 然而, they are supportive of the consolidated changes for North American reporting which are being done in line with their current rules.
Ongoing dialogue with our DDR clients has been critical in boosting their readiness for the CFTC’s rule changes. Our GTR leadership team hosts weekly working group calls for all clients with reporting obligations in North America, as well as information sharing sessions specific to swap execution facilities and Canadian clients. We have also hosted a number of webinars and other live forums to educate our clients and the industry ahead of December’s compliance date.
我们也认识到早期用户接受测试(UAT)的价值, so in late May of this year DDR made our UAT Simulator available to all clients, supporting the testing of system changes associated with the upcoming rule revisions. 这个环境可以用来验证提交和测试确认, 帮助确保报告的交易将在上线时被接受. 完整的贸易国贸易协定, 估值和抵押品报告将于2022年8月提供, 公共价格发布UAT (PPD)将于2022年9月开放.
使用存简化复杂性
随着CFTC第一阶段实施的临近, 我们建议公司审查其贸易报告基础设施, controls and processes and consider finding a service that delivers the greatest value and readies them for the regulatory changes taking effect globally in 2022 and beyond. 存的报告中心® 提供高效的交易前和交易后报告解决方案, helping firms manage the complexities of multiple regulatory mandates across many jurisdictions.
公司可以利用我们的经验的广度和深度 存咨询服务 转变贸易后业务经营方式, 提高效率, 降低风险，降低成本. For those nearing the finish line of their preparations, the 存咨询服务 also offer a CFTC测试包 to empower firms with the tools they need to verify their system’s readiness for the new rules.
在CFTC重写的第一阶段之后, 还有很多工作要做, 不仅在北美，而且在全球. 存 is waiting for more information from the CFTC regarding the expected date of the phase two draft rules regarding implementing the ISO 20022 XML schema and the Unique Product Identifier (UPI). We are reviewing the recently published draft of Canada’s rule proposals which we expect to be in line with CFTC. And we will begin working with the SEC on their rules as their no-action relief will expire after four years.
The collaboration and resulting gains in alignment being achieved among all 15 North American regulators demonstrates that harmonization is possible and could lead to effective data amalgamation. As global regulators look to implement their own revised trade reporting rules, 存将继续通过与行业合作来支持我们的客户, 包括全球监管机构, 市场参与者和行业标准制定机构, 确保数据协调目标的持续一致性.