Reporting and Governance
Leo Labeis

One of the challenges facing financial institutions when it comes to compliance is the lack of standardisation across regions. This has led to a duplication of processes, increasing the cost, complexity and operational risk of trade reporting and degrading the quality of the data collected by regulators globally.  By Leo Labeis, CEO at REGnosys

The Commodity Futures Trading Commission’s (CFTC) rewrite of swaps reporting rules – known as the CFTC Rewrite – is one of several upcoming changes to global trade reporting regimes looking to tackle the problem of a lack of standardisation across regions. The new extended deadline for the amendments, which come into play on December 5, 2022, has afforded firms valuable time to review their reporting practices. Digital Regulation Reporting (DRR) has emerged as a practical solution in this transition, allowing for a more strategic approach to data management and greater industry-wide collaboration.  

With less than three months until the amendments go live, firms must ensure that they are compliant with the new requirements. Here, we trace the origin of the CFTC Rewrite and explain how DRR can help facilitate the compliance process.     

Standardising post-trade  

The transparency requirements for over-the-counter (OTC) derivatives transactions, first enacted as part of the global financial reform at the G20 Summit in 2009, triggered multiple overlapping requirements across jurisdictions.       

The US was the first to implement those changes with the Dodd-Frank Act. The current CFTC requirements have been in place since 2012 and other jurisdictions followed in subsequent years. A decade on, these reporting regimes are now being reviewed and the CFTC Rewrite is the first major overhaul within the G20.    

The amendments are born out of the drive to achieve greater harmonisation between jurisdictions and higher data quality. The Committee on Payments & Market Infrastructures and the International Organization of Securities Commissions (CPMI-IOSCO) working group of global regulators has been at the heart of this shift. In 2018, the group published its Critical Data Elements (CDE) to work alongside other common standards including the Unique Product Identifier (UPI) and Unique Trade Identifier (UTI).      

The first phase of the CFTC Rewrite this year adopts the CDE and UTI, with implementation of the UPI to follow in 2023.  Although not every regulator is adopting these standards in precisely the same way, it is undoubtedly a significant improvement on the existing disjointed landscape.      

DRR’s role 

DRR is a global industry-led programme to mutualise the cost of interpreting and complying with reporting requirements. Rather than each firm performing their own interpretation, DRR allows them to standardise that interpretation, encode the rules into a “model” and store it in a digital, openly accessible format. As such, it is a valuable mechanism to mitigate any divergence between jurisdictions.   

DRR also digitises the regulators’ sample trade scenarios that they may provide in their technical specifications (usually as PDF documents) to illustrate the workings of the rules, as is the case with the CFTC Rewrite. DRR stores those scenarios as synthetic data samples which firms can use to test their implementations and demonstrate that it performs as expected against the rules.       

On top of the common rules and the CFTC-specific logic, extensions are built for reporting into each of the trade repositories.    

Historically, each trade repository required reporting firms to submit data in a specific format that they determined, before applying their own data transformation for consumption by the regulator. The mandating of the ISO 20022 format, consistent with a push for more standardisation, changes that process by shifting the responsibility from trade repositories to the reporting firm. Going forward, each firm will be required to report to the trade repositories directly. Although, in the CFTC Rewrite case, that mandate has been postponed to 2023, DRR will ease that process in future by also standardising the transformation into ISO 20022.    

Deployment & implementation   

The CFTC Rewrite build in DRR started in late 2021 and is now largely complete with more than 90% of the CFTC reportable fields covered.   

The DRR model is now undergoing a quality assurance process to ensure it is a complete and accurate representation of the rules. Once trade associations sign off on the model, reporting participants will be able to use DRR as a resource for their internal production build. In the fourth quarter, further testing will ensure that the content the model is producing is in line with the trade repositories’ expectations.     

As firms enter into the last stretch of their own build, they must now prepare for a full end to end test in the context of their implementation choice. Firms can leverage DRR by either building their own system on it or deploying a third-party platform that does. Whichever path firms choose to go down, they should ensure that rigorous user acceptance testing is completed ahead of the December deadline so that DRR is fully embedded before the new requirements go live. 

For years, firms have struggled with the volume and complexity of reporting requirements because of the fragmented nature of their systems and siloed approaches. DRR has emerged as a primary tool in driving more collaborative efforts, helping to deliver an open source, standardised and machine-executable interpretation of rules. With several reporting amendments set to come into play in the years to come, firms which invest now and implement this new approach will have a strong foundation for not only the CFTC Rewrite, but also for future industry updates. 

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