CFTC Reminds SDs and MSPs of Swap Reporting Obligations

Katten Muchin Rosenman LLP
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The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission has issued an advisory to remind swap dealers (SDs) and major swap participants (MSPs) of their swap data reporting obligations. The advisory lists examples of reporting issues that appear with some frequency, including readily apparent errors, incomplete reporting, duplicative swap reporting, calculation errors and reporting delays. The advisory also provides examples of reporting practices that SDs and MSPs may want to consider, including the implementation of data gatekeepers, automated review of reported data, erroneous record checks, improved change management practices, prompt data correction and proper supervision of third-party service providers.

The advisory is available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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