What are the Part 43 reporting deadlines?
The deadline for Part 43 reporting remains unchanged and must be reported ASATP (As Soon As Technologically Practicable) after execution. (see §43.3)
The deadline for Part 43 reporting remains unchanged and must be reported ASATP (As Soon As Technologically Practicable) after execution. (see §43.3)
What are the Part 45 reporting deadlines?
The CFTC has extended the Part 45 reporting for SEFs, DCMs, SDs, MSPs, and DCOs to the end of the next business day following the execution date instead of immediately after execution with certain backstops. CFTC also extended the deadline for all other counterparties to the end of the second business day following the execution date. (see §45.3(a) and (b))
What are my obligations to report Valuations?
The amendments to part 45 retain the obligation for SDs/MSPs/DCOs to submit valuations daily but clarifies it is “each business day” as that term is defined in § 45.1. For all other counterparties that currently report valuation data quarterly, the requirement to report valuations has been removed. (see § 45.4(c)(2))
What are my obligations to report Margin/Collateral?
The CFTC, under the new rules requires SDs/MSPs to report margin and collateral data "each business day" with a view that the Commission's ability to monitor for systemic risk will be significantly improved. (see § 45.4(c)(2))
What is the Unique Trade Identifier on a transaction ?
UTI and USI are two fields that are available to populate the unique trade identifier.
A USI will no longer be permissible for swaps executed on or after the compliance date of Dec 5, 2022. The regulation prohibits SDRs from accepting USIs for all new transactions (e.g., <Action> = 'NEWT').
All new transactions reported after the Compliance Date must utilize the UTI field.
How is Part 43 and Part 45 transaction data reported?
As per the new reporting requirements, Part 43 and Part 45 transaction data must be reported separately and cannot be combined into a single submission record as previously allowed.
Note: The Part 43 and Part 45 records must each be reported with <Action> = 'NEWT' for the first submission to the KOR SDR and the appropriate <Action> for continuation events as applicable.
As per the new reporting requirements, Part 43 and Part 45 transaction data must be reported separately and cannot be combined into a single submission record as previously allowed.
Note: The Part 43 and Part 45 records must each be reported with <Action> = 'NEWT' for the first submission to the KOR SDR and the appropriate <Action> for continuation events as applicable.
What obligations do I have as a counterparty to verify data submitted to the KOR SDR?
Each reporting counterparty shall verify that there are no errors in the swap data for all open swaps that the reporting counterparty reported, or was required to report, to KOR SDR. Such verification shall be conducted by utilizing the “mechanism” provided by KOR SDR to compare all swap data for each open swap for which it serves as the reporting counterparty with all swap data contained in its internal books and records for each swap, to verify that there are no errors in the swap data maintained by KOR SDR. (see § 45.14 for further details).
Each reporting counterparty shall verify that there are no errors in the swap data for all open swaps that the reporting counterparty reported, or was required to report, to KOR SDR. Such verification shall be conducted by utilizing the “mechanism” provided by KOR SDR to compare all swap data for each open swap for which it serves as the reporting counterparty with all swap data contained in its internal books and records for each swap, to verify that there are no errors in the swap data maintained by KOR SDR. (see § 45.14 for further details).
What "mechanism" is KOR SDR providing counterparties to verify data?
The KOR SDR intends to make available a report via a self-service User Interface that allows each user to access all swap data maintained by the KOR SDR. This mechanism shall allow sufficient access, provide sufficient information, and be in a form and manner to enable every user to perform swap data verification as required under § 45.14.