What is CFTC Transaction Reporting?

CFTC reporting is part of the regulatory framework under the Dodd-Frank Act, specifically Title VII, which was introduced on the back of the Global Financial Crisis to empower United States regulators to conduct effective market surveillance to support financial market stability and reduce systemic risk through increased transparency across the derivatives markets.

Firms engaging in over-the-counter derivatives trading within the United States are required to submit transaction details to a registered Swap Data Repository (SDR), such as DTCC, ICE Trade Vault and Chicago Mercantile Exchange (CME).

These reporting obligations consist of two main components:

- Real-time reporting under Part 43, aimed at providing market transparency by disclosing pricing information promptly.
- Transaction reporting under Part 45, enabling regulators to monitor the market for systemic risks.

Proposed Changes

There have been several revisions and updates to the original draft regulations since the implementation of the Dodd-Frank Act in 2012.

These revisions were often made to clarify requirements, address emerging issues, and improve the effectiveness of the regulatory framework. The CFTC Rewrite that came into effect in late 2022 is the latest revision to the ruleset. There were significant changes to the reporting rules that were seen as a re-calibration towards a more globally harmonised transaction reporting paradigm.

In December 2023, the CFTC released a proposal to add nineteen data elements to the reporting obligations that mostly affect the commodity asset class.