Do I need to report Prime Broker/Tigger/Mirror Swaps?

A Mirror Swap is not a Publicly Reportable Swap Transaction. Execution of a Trigger Swap, shall be deemed to occur at the time of the Pricing Event for such Trigger Swap.

Part 43: Prime Broker Swaps

A Mirror Swap is not a Publicly Reportable Swap Transaction. Execution of a Trigger Swap, shall be deemed to occur at the time of the Pricing Event for such Trigger Swap.

With respect to a given set of swaps, if it is unclear which is, or are the mirror swap(s) and which is the related Trigger Swap (including, but not limited to, situations where there is more than one Prime Broker counterparty within such set of swaps and situations where the Pricing Event for each set of swaps occurs between Prime Brokerage Agents of a common Prime Broker), or if under the Prime Brokerage Agency Arrangement, the Trigger Swap would occur between two Prime Brokers, the Prime Broker(s) shall determine which of the Prime Broker Swaps shall be treated as the Trigger Swap and which are mirror swaps.

Trigger Swaps shall be reported in accordance with the following:

    1. Trigger Swaps executed on or pursuant to the rules of a SEF or DCM shall be reported pursuant to CFTC Rule 43.3 (a)(2); and
    2. Off-facility Trigger Swaps shall be reported pursuant to CFTC Rule 43.3 (a)(3), except that if a counterparty to a Trigger Swap is a SD that is not a Prime Broker with respect to that Trigger Swap, then that SD counterparty shall be the Reporting Counterparty for the Trigger Swap.

References: CFTC Rule(s) §43.3(a)(6)