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  2. CFTC
  3. Continuation and Updates

Who has to report trade updates?

For each swap, regardless of Asset Class, Reporting Counterparties and DCOs required to report required swap continuation data shall report life-cycle event data for the swap electronically to a Swap Data Repository within the applicable deadlines.

Clients must follow the KOR SDR Technical Specifications to submit continuation data. For open swaps, all continuation data submissions must include all applicable fields and be submitted according to the format and validations prescribed by the SDR at the time of submission and not at the time the trade was initially executed.

Clients shall not submit continuation data messages that do not update any SDR fields or correct a previous submission.

KOR SDR shall provide the Commission and the Reporting Counterparty, or their Delegated Reporter with a daily report of all swaps with continuation data reported that day that did not meet the prescribed timeline. It is the duty of the Reporting Counterparty, or their third-party representative to review these reports and identify any systematic issues in reporting that need to be resolved and make necessary updates as soon as practicable.

Continuation late reporting is based on the SDR calculated Submission Timestamp vs. the Event Timestamp. The Submission Timestamp is calculated based on when the swap message is received by the SDR and has passed all SDR validations. Business Days means the twenty-four-hour day, on all days except Saturdays, Sundays, and legal holidays, in the location of the reporting party or registered entity reporting data for the swap. For Reporting Counterparties, the US Federal Holiday calendar and Eastern time is used unless the Client that is the Reporting Counterparty provided a different calendar, in which their local calendar and time zone are used.

References: CFTC Rule(s) §45.4(a) and 43.2.