Environmental Credits and Environmental Credit Obligations
SIFMA provided comments to the Financial Accounting Standards Board (FASB) on the Proposed Accounting Standards Update—Environmental Credits and Environmental Credit…
Issue
OTC Derivatives→
Excerpt
Mr. Christopher Kirkpatrick
Secretary
U.S. Commodity Futures Trading Commission
1155 2P1 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”) 1 are writing to request that the U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) extend the comment period for the Proposed Amendments to the Commission’s Regulations Relating to Certain Swap Data Repository and Data Reporting Requirements (“Proposal”),2 which is scheduled to close on July 29,2019, for an additional ninety (90) days.
In 2017, the Commission announced its intent to modify certain reporting requirements under Parts 43, 45, and 49 of the Commission’s regulations by publishing the Roadmap to Achieve High Quality Swap Data (“Roadmap”).3 The Proposal is the first of three forthcoming amended rulemakings intended to achieve the goals laid out in the Roadmap-to improve the quality, accuracy, and completeness of data reported to the Commission.4 As the Commission points out in the Proposal, all three amended rulemakings address interconnected issues. We agree with the Commission that the Proposal and the forthcoming additional two rulemakings are integrally related and should be evaluated together.
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,5 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, 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.