Mr. Christopher J. Kirkpatrick
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington, DC 20581
RE: Comments on Amendments to the Swap Data Recordkeeping and Reporting Requirements (RIN 3038–AE31), Amendments to the Real-Time Public Reporting Requirements (RIN number 3038–AE60), Certain Swap Data Repository and Data Reporting Requirements (RIN number 3038–AE32) 1
Dear Mr. Kirkpatrick,
The International Swaps and Derivatives Association, Inc. (“ISDA”)2 and the Securities Industry and Financial Markets Association (“SIFMA”)3 (collectively, “the Associations” or “we”) appreciate the opportunity to provide comments to the U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) in response to the proposed amendments to the CFTC’s swap data reporting rules
referenced above (“Proposals”).
The Associations support the Commission’s efforts to harmonize with global CPMI-IOSCO reporting data elements, streamline reporting, extend regulatory reporting deadlines, and provide specificity about the swap data required to be reported. We believe that once finalized, the proposed changes will improve the quality, accuracy, and completeness of the data reported to the Commission.
Our members are strongly committed to maintaining the safety and efficiency of the U.S. swaps markets and hope that the Commission will consider our suggestions, as they reflect the extensive knowledge and experience of the trading and operational professionals within our membership who are subject to the Commission’s swap data reporting regulations as well as those of multiple other reporting jurisdictions globally.
In order to respond in the most effective manner, we identify in the Executive Summary the areas where the Proposals could be further improved and then answer certain questions included in the Proposals. Due to the technical nature of the Proposals, we believe it is easier to provide concrete answers to specific questions, thus avoiding unnecessary ambiguity in describing specific industry terms and practices.