How do I fill out the CFTC Notification Form?

Question:

One transaction Q7(a) could have multiple associated swap reports

Q7(b). We believe classification of swap reports could fall into 4 types: P43, P45 transaction, P45 valuation, and P45 margin/collateral. Therefore Q7(b) responses could fall into one of these 4 types.

So, if the response to 7(a) is three (i.e. UTIs), and two report types were impacted, then market participants believe the response to Q7(b) would be 6. Is our understanding correct for Q7(a) and Q7(b) ?

CFTC Feedback:

CFTC Staff do appear to be anticipating high volumes of Notification Forms at the onset of CFTC rewrite reporting. 

CFTC staff expect the answer for 7(b) to be higher than 7(a).

CFTC staff were not in agreement with the WG’s suggested reading of Q7(b) (i.e. if the response to 7(a) is three (i.e. UTIs), and two report types were impacted, then market participants believe the response to Q7(b) would be 6). They expect a much higher number as a response to 7(b). They gave an example that if the same error existed for 30 days, the response to 7(b) should reflect the multiplier of 30. However, when asked, they weren’t certain what “swap reports” in Q7(b) refer to (e.g. whether it is or is not a reference to messages sent to the SDR) since the question was drafted by legal, so they plan to reach out to the author on their legal team and come back with further clarity or guidance.