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Extension Request for Certain Swap Data Repository and Data Reporting Requirements

Issue

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Summary

SIFMA and ISDA sent comments to the U.S. Commodity Futures Trading Commission regarding another extension to comment period for the Proposed Amendments to the Commission’s Regulations Relating to Certain Swap Data Repository and Data Reporting Requirements, which is scheduled to close on October 28, 2019, for an additional ninety (90) days.

The Proposal is the first of three forthcoming amended rulemakings intended to improve the quality, accuracy, and completeness of data reported to the Commission. On July 25, 2019, the Commission granted our request to extend the comment period of this Proposal for 90 days. Our initial request for extension stemmed from the fact that it would be difficult for market participants to comment on the Proposal given that the other two rulemakings had not yet been proposed and all three rulemakings address interconnected issues. Since such other rulemakings have yet to be proposed, we seek another ninety-day extension.

PDF

Submitted To

CFTC

Submitted By

SIFMA, ISDA

Related Committee(s)

  • Swap Dealer Committee

Date

8

October

2019

Excerpt

Mr. Christopher Kirkpatrick
Secretary
U.S. Commodity Futures Trading Commission
1155 21st NW
Washington DC 20581

Re:      Request for an Extension of the Comment Period for Certain Swap Data Repository and Data Reporting Requirements [RIN Number 3038-AE32]

Dear Mr. Kirkpatrick:

The International Swaps and Derivatives Association, Inc. (“ISDA”) and Securities Industry and Financial Markets Association (“SIFMA”)(together, the “Associations”) are writing to request that the U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) another extension to comment period for the Proposed Amendments to the Commission’s Regulations Relating to Certain Swap Data Repository and Data Reporting Requirements (“Proposal”), which is scheduled to close on October 28, 2019, for an additional ninety (90) days.

The Proposal is the first of three forthcoming amended rulemakings intended to improve the quality, accuracy, and completeness of data reported to the Commission. On July 25, 2019, the Commission granted our request to extend the comment period of this Proposal for 90 days. Our initial request for extension stemmed from the fact that it would be difficult for market participants to comment on the Proposal given that the other two rulemakings had not yet been proposed and all three rulemakings address interconnected issues. Since such other rulemakings have yet to be proposed, we seek another ninety-day extension.

As stated in our initial request for extension, although the Commission anticipates re-opening the comment period for the Proposal when it publishes its proposed changes to Parts 43 and 45 in order to provide market participants with the opportunity to comment collectively on all three rulemakings, it is difficult for market participants to provide meaningful comments on certain aspects of the Proposal without first reviewing the other two proposals. For example, as we noted in our initial request, market participants are expected to evaluate and comment on the Commission’s proposed verification requirements without the benefit of knowing what the Commission will be proposing with respect to the number, format, and types of data fields that will be expected to be verified within the proposed 48-hour or 92-hour timeframe, depending on the type of market participant.

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