Corrections

What should I do for over or under-reporting?

Sometimes bad things happen and messages don't make it to the SDR due to a human or technical issue. Or data not required to be reported is sent to the system. Once spotted, the over or under-reported data needs to be corrected in the SDR.

Missing messages (under-reported) or messages not needed to be reported (over-reported) are both caught under the obligation for firm to ' completely and accurately report Swap Data' as per CFTC Rule(s) §45.14(a)(1)

As such over or under-reporting is subject to requirements to correct errors ASATP and notify the regulator if cannot do so with 7 days of issue discovery as per CFTC Staff Letter No. 22-06

For complete background to correct errors please refer to here: 

What are the requirements to correct errors?

 

KOR Financial is working on analytical tools that will help to spot over and under-reporting.  The "missing" reports we offer is the first step to identifying issues. Once discovered the above legal requirements dictate that missing or superfluous data:

  1. be considered as an error based on the regulation above
  2. be corrected ASATP:
    1. If correcting the data is not possible within 7 days of discovery, must notify the CFTC as per CFTC Staff Letter No. 22-06.
    2. over-reported messages should be removed through an action type Error (as detailed in the KOR SDR technical specification)
    3. missing data must be reported as per usual reporting standards
    4. if client believes the issue in correcting the data is related to the KOR SDR system (for example (UPI, validations, connectivity, etc..) then must enter a KOR support ticket (How do I create a support ticket) as soon as practicable but not later than the Business Day following the discovery.

Note that there is no need to notify KOR SDR of over or under-reporting unless the client believes the issue in correcting the data within 7 days is due to KOR SDR as above or requires other assistance.