SIFMA AMG Swap and Security-Based Swap Reporting Joint RFC
Summary
SIFMA AMG 1 provided comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the review of their respective swap and security-based swap data reporting regimes. 2
Excerpt
AMG commends the CFTC and SEC for undertaking a comprehensive review of these regimes after more than a decade of implementation experience. This review presents an opportunity to simplify, rationalize and harmonize the reporting regimes while maintaining regulatory access to high-quality data. Buy-side market participants, in particular, support further amendments to swap and security-based swap data reporting regimes that advance clearly defined regulatory purposes and market-transparency objectives.
AMG believes there are four fundamental principles that should be kept in mind during the development of this reform, all of which AMG has emphasized in previous letters.
- First, AMG believes enhancing data quality and consistency should be prioritized.
Accurate, consistent, and usable data provides much greater value to regulators and market participants than simply the volume of reporting obligations or the quantity of data reported. As such, efforts should focus on reducing reporting complexities that contribute to inaccurate reporting and reconciliation challenges.
- Second, harmonization between the CFTC and SEC should remain a core objective. Alignment with global standards, where practical, should also be prioritized.
Harmonization between the agencies and alignment with global standards allows for consistency in reporting expectations, allowing market participants to build and maintain
more efficient reporting processes. It also reduces the risk of inconsistencies and inaccuracies borne from conflicting requirements and unnecessary complexities. 3
- SIFMA AMG brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms whose combined assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.
- 2 Joint Request for Comment on Swap and Security-Based Swap Data Reporting, 91 Fed. Reg. 37877 (June 24, 2026).
- See also SIFMA, Comment Letter on the Proposed Rule re: Regulation SBSR—Reporting and Dissemination of
Security-Based Swap Information (May 2017), available at: https://www.sifma.org/wp-content/uploads/2017/05/sifma-amg-submits-comments-to-the-sec-on-regulation-sbsr.pdf; SIFMA, Swaps Reporting Review by the Commodity Futures Trading Commission’s Division of Market Oversight (Aug. 18, 2017), available at https://www.sifma.org/advocacy/letters/cftc-dmo-swaps-reporting-review-and-roadmap.