The Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have issued a joint request for public comment on harmonizing data reporting requirements for security-based swap and swap markets. With a 60-day comment period following Federal Register publication, you have a limited time to evaluate your current reporting infrastructure and prepare for what could be the most significant shift in swap data reporting since the Dodd-Frank Act.
This template will help you inventory your current reporting framework and identify gaps before harmonized requirements take effect.
Purpose of the Template
Use this template to map your organization's current swap data reporting obligations across both SEC and CFTC frameworks. It establishes a baseline that allows you to:
- Identify where you're maintaining duplicate reporting processes for similar data points.
- Spot areas where harmonization could reduce your operational burden.
- Document technical dependencies that might complicate migration to a unified framework.
- Build a fact-based response to the agencies' request for comment.
This isn't a compliance checklist. It's a diagnostic tool to show where harmonization creates opportunities and where it requires additional work.
Prerequisites
Before using this template, gather:
- Your current security-based swap data reporting procedures (SEC-regulated).
- Your current swap data reporting procedures (CFTC-regulated).
- System architecture documentation showing how you generate, validate, and transmit swap data.
- Access to the person who configures your reporting systems.
You'll also need clarity on which agency's framework governs each product type you report. If you're unsure whether a specific instrument falls under SEC or CFTC jurisdiction, note that in the template and consult legal input before submitting comments.
The Template
Copy this into a spreadsheet or document management system where your compliance, legal, and technology teams can access it:
SWAP DATA REPORTING HARMONIZATION READINESS ASSESSMENT
Organization: [Your legal entity name]
Assessment Date: [Date]
Prepared By: [Name, title]
Section 1: Current Reporting Scope
| Data Category | SEC Framework | CFTC Framework | Overlap? | Notes |
|---|---|---|---|---|
| Transaction reporting | [Yes/No/Partial] | [Yes/No/Partial] | [Yes/No] | [Describe differences] |
| Regulatory reporting | [Yes/No/Partial] | [Yes/No/Partial] | [Yes/No] | [Describe differences] |
| Public dissemination | [Yes/No/Partial] | [Yes/No/Partial] | [Yes/No] | [Describe differences] |
| Historical reporting | [Yes/No/Partial] | [Yes/No/Partial] | [Yes/No] | [Describe differences] |
Purpose: This section identifies where you're reporting similar data under different requirements.
Section 2: Data Elements and Identifiers
| Data Element | SEC Requirement | CFTC Requirement | Standardized? | Reconciliation Process |
|---|---|---|---|---|
| Counterparty identifier | [Describe format] | [Describe format] | [Yes/No] | [How you manage differences] |
| Product identifier | [Describe format] | [Describe format] | [Yes/No] | [How you manage differences] |
| Venue identifier | [Describe format] | [Describe format] | [Yes/No] | [How you manage differences] |
| Timestamp format | [Describe format] | [Describe format] | [Yes/No] | [How you manage differences] |
Purpose: This section reveals where you're translating the same information into different formats for each agency.
Section 3: Technology Infrastructure
| System Component | Supports SEC | Supports CFTC | Vendor/In-House | Modification Complexity |
|---|---|---|---|---|
| Data capture system | [Yes/No] | [Yes/No] | [Name or "Internal"] | [Low/Medium/High] |
| Validation engine | [Yes/No] | [Yes/No] | [Name or "Internal"] | [Low/Medium/High] |
| Transmission platform | [Yes/No] | [Yes/No] | [Name or "Internal"] | [Low/Medium/High] |
| Error management | [Yes/No] | [Yes/No] | [Name or "Internal"] | [Low/Medium/High] |
Purpose: This section shows whether harmonization means updating one system or rebuilding your entire reporting stack.
Section 4: Operational Complexity
Describe your current process for:
- Determining which framework applies to a new product: [Your process]
- Handling reporting errors or resubmissions: [Your process]
- Training staff on reporting requirements: [Your process]
- Maintaining documentation of reporting decisions: [Your process]
Estimate the staff time you spend on:
- Maintaining separate SEC and CFTC reporting procedures: [Hours per month]
- Reconciling data between frameworks: [Hours per month]
- Managing vendor relationships for reporting systems: [Hours per month]
Purpose: This section quantifies the burden that harmonization might reduce.
Section 5: Implementation Concerns
If the agencies harmonize reporting requirements, what would be your biggest challenges?
- System modifications (describe): ___________
- Staff retraining (describe): ___________
- Vendor coordination (describe): ___________
- Historical data migration (describe): ___________
- Other (describe): ___________
What transition period would you need?
[Your answer]
What would make implementation easier?
[Your answer]
How to Customize It
Adapt this template to your organization's reporting profile:
If you report only to one agency: Remove the comparison columns and use this to document your current state. When harmonization happens, you'll have a clear baseline showing what changes.
If you use third-party reporting services: Add a column tracking which vendor handles which requirement. You'll need to know whether harmonization means renegotiating one contract or coordinating changes across multiple vendors.
If you report across multiple legal entities: Create separate assessments for each entity, then build a summary view. Harmonization might affect your entities differently depending on their product mix.
If you're preparing comments for the agencies: Use Section 5 as the foundation of your response. The agencies specifically asked for input on operational and technological implications. Your completed template gives you concrete examples to cite.
Validation Steps
After you complete the template, walk through these checks:
Accuracy check: Share Section 1 and Section 2 with the people who actually submit your swap data reports. Do they agree with your characterization of current requirements? If not, revise before you rely on this assessment.
Completeness check: Review the agencies' request for comment (published in the Federal Register 60 days before the comment deadline). Did they raise topics your template doesn't address? Add rows or sections as needed.
Stakeholder check: Show Section 3 and Section 4 to your technology and operations teams. Do your complexity estimates match their experience? If you've underestimated the effort required for system changes, adjust your implementation timeline in Section 5.
Decision-maker check: Brief your chief compliance officer or general counsel using this template. Can they make informed decisions about whether to submit formal comments to the agencies? If not, identify what additional analysis you need.
The SEC and CFTC are asking whether changes to reporting requirements would enhance market transparency, reduce operational complexity, and improve data quality. Your completed template tells you whether harmonization delivers those benefits for your organization or whether it creates new burdens that offset the gains. Either answer is valuable, but you need to know which one applies to you before the comment period closes.
