FIA, joined by ISDA, has responded to the CFTC’s notice of intent to renew the collection of large trader reporting (LTR) data for physical commodity swaps. The associations reiterate and build on requests they have made in recent years for the CFTC to sunset the LTR rules for swaps, which were envisioned as a temporary measure while the CFTC stood up its comprehensive swap reporting framework under Dodd-Frank.
That framework has been established for over a decade now and has undergone a substantial update in recent years. As such, the associations believe it is an appropriate time to phase out LTR swap reporting.
The response notes that data provided to the CFTC by swap data repositories (SDRs) enable it to surveil swaps that are in scope of federal position limits. Meanwhile, reporting entities (swap dealers and clearing members) expend substantial resources submitting detailed and extensive LTR swap reports to the CFTC.
“By sunsetting the Swaps LTR Rules, the Commission could redirect its limited resources more efficiently to analyzing the swaps data provided by SDRs and surveilling compliance with position limits on economically equivalent swaps,” the associations say.
Read the response in full.