SIFMA Swap and Security-Based Swap Reporting Joint RFC
Summary
SIFMA 1 and the International Swaps and Derivatives Association, Inc. (ISDA) 2 provided comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) in response to the Joint Request for Comment on Swap and Security-Based Swap Data Reporting. 3
Excerpt
Swap and SBS transaction reporting are important elements of broader measures that have been taken to enhance the transparency, and consequently the safety and efficiency, of derivatives markets. The Associations have long supported these goals. We have contributed on behalf of our members on multiple levels to develop swaps and SBS data reporting requirements in the US, consistent international standards across jurisdictions, and open industry standards for policymakers and market participants.
The Associations commend the CFTC and SEC’s joint effort to improve swap and SBS data reporting. It will help make such reporting more meaningful for policymakers and market participants by providing better and more consistent data. At the same time, it will reduce unnecessary operational complexity, minimize compliance costs, and enhance market efficiencies, without compromising regulatory oversight.
Our comments 4 are organized in five parts. Part I articulates and summarizes the strategic priorities that frame our feedback:
- Streamlining and clarifying reporting requirements;
- Aligning the SEC’s SBS reporting rules with the revised CFTC swap data reporting rules;
- Improving the utility of the public price dissemination;
- Conducting with the industry a holistic review of the reporting fields; and
- Leveraging technological advancements such as ISDA Digital Regulatory Reporting (“DRR”) to improve data quality and support consistent implementation.
- SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.
- Since 1985, ISDA has worked to make the global derivatives markets safer and more efficient. Today, ISDA has over 1,000 member institutions from 79 countries. These members comprise a broad range of derivatives market participants, including corporations, investment managers, government and supranational entities, insurance companies, energy and commodities firms, and international and regional banks. In addition to market participants, members also include key components of the derivatives market infrastructure, such as exchanges, intermediaries, clearing houses and repositories, as well as law firms, accounting firms and other service providers. Information about ISDA and its activities is available on the Association’s website: www.isda.org.
- CFTC and SEC, Joint Request for Comment on Swap and Security-Based Swap Data Reporting (June 24, 2026),
https://www.govinfo.gov/content/pkg/FR-2026-06-24/pdf/2026-12742.pdf. - Unless otherwise expressly indicated, the comments and suggested solutions in this letter are generally meant for both CFTC swaps and SEC SBS – this is reflective of the Associations’ view that the revised CFTC swap data reporting and SEC SBS reporting rules should, generally-speaking, be harmonized as a result of the Agencies’ current streamlining and harmonization initiative.