ARTICLE
2 December 2020

Effective Date And Compliance Deadlines Set For CFTC Amendments To Swap Data Reporting Requirements

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The effective date for the amendments is January 25, 2021.
United States Finance and Banking

Final rule amendments to swap data reporting requirements under CFTC Rules Parts 43, 45, 46 and 49 were published in the Federal Register (see  85 FR 7542285 FR 75503 and 85 FR 75601). The effective date for the amendments is January 25, 2021.

Swap data repositories, swap execution facilities, derivatives clearing organizations and reporting counterparties must comply with all amendments by May 25, 2022, with the exception of Rule 43.4(h) ("Swap transaction and pricing data to be publicly disseminated in real-time - cap sizes") and Rule 43.6 ("Block trades and large notional off-facility swaps") which have a compliance date of May 25, 2023.

See  related coverage for more information on the background and impact of the adopted changes.

Primary Sources

  1. Federal Register: Certain Swap Data Repository and Data Reporting Requirements
  2. Federal Register: Real-Time Public Reporting Requirements
  3. Federal Register: Swap Data Recordkeeping and Reporting Requirements

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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