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Contents

General

Q. What is the deadline for compliance (“Compliance Date”) with the amended swap data reporting rules (Parts 43, 45, 46 and 49)?
A. Dec 5, 2022 for all amended rules except §§ 43.4(h) and 43.6. The compliance date for §§ 43.4(h) and 43.6, which govern block thresholds and cap sizes, is Dec 4, 2023.

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Q. Who should I contact for inquiries? 
A. Please contact repositorysupport@cmegroup.com for any initial inquiry. If you have a regular relationship manager, you may also copy that person in the email. 

Reporting to the SDR

Q. What are the Part 43 reporting deadlines?
A. The deadline for Part 43 reporting remains unchanged and must be reported ASATP (As Soon As Technologically Practicable) after execution. (see §43.3)

Q. What are the Part 45 reporting deadlines?
A. The CFTC has extended the Part 45 reporting for SEFs, DCMs, SDs, MSPs, and DCOs to the end of the next business day following the execution date instead of immediately after execution with certain backstops. CFTC also extended the deadline for all other counterparties to the end of the second business day following the execution date. (see §45.3(a) and (b))

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Q. What is the Unique Trade Identifier on a transaction ?
A. UTI and USI are two fields that are available to populate the unique trade identifier.
A USI will no longer be permissible for swaps executed on or after the compliance date of Dec 5, 2022. The regulation prohibits SDRs from accepting USIs for all new transactions (e.g., <Action> = 'NEWT'). However, any transaction reported to CME SDR prior to the Compliance Date using a USI, can continue to be amended using the USI.  Previously, the USI comprised of a separate USI Namespace and USI field(s). Going forward, the USI Namespace and USI will be combined into a single field called <USI> of 42 characters long.
All new transactions reported after the Compliance Date must utilize the UTI field.
Note: Uniqueness on a transaction is across the UTI, USI, and all asset classes. For example, a value populated in USI for a given asset class must not have been previously used in the USI or UTI fields for any other asset class.

Submission Process

Q. Which methods are available to submit data to the SDR?
A. Web Services (Rest API), User Interface, and Secure FTP continue to be offered as the the submission methods to the SDR. Between the three available methods, the Web Services and User Interface submission methods will have an improved user experience and few technical changes in the way data is submitted and responses retrieved. For more information, please contact repositorysupport@cmegroup.com.

Q. What are the technical changes in the submission process to the SDR?
A. Submissions via the Web Services and User Interface will see user experience changes.  The submissions will move to a "asynchronous" model, which means the user will receive a request ID in response when the file has been received by the CME SDR. This allows the user to return to the browser (if using the User Interface upload feature) or terminal (if using the Web Services API) to continue to work as normal while their request is being handled in the background. To look up the status of the submission, the user can navigate to Submission Tracker screen on the User Interface or initiate another Web Service call and pass the previously generated request ID as a parameter to receive the status or final ACK or NACK on the submission.

Q. In which format is data reported to the SDR?
A. CSV (Comma Separated Flat File) will be the only supported format.

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Q. Is there a column ordering constraint on the CSV file?
A. There is no ordering constraint. Although the column headers must match exactly to the field names in the CME SDR CSV Technical Specification. The submission template can be the same across all asset classes but only the relevant fields for that asset class must be populated.

Data Access and Verification Verification 

Q. What obligations do I have as a counterparty to verify data submitted to the CME SDR?
A. Each reporting counterparty shall verify that there are no errors in the swap data for all open swaps that the reporting counterparty reported, or was required to report, to CME SDR. Such verification shall be conducted by utilizing the “mechanism” provided by CME SDR to compare all swap data for each open swap for which it serves as the reporting counterparty with all swap data contained in its internal books and records for each swap, to verify that there are no errors in the swap data maintained by CME SDR. (see § 45.14 for further details).

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Q. Will I be able to continue to access my previously reported swap data after the implementation of new rules?
A. Yes. 

Testing and Connections

Q. When will the UAT environment be available? 
A. The UAT environment for Submissions will be available effective Jul 21, 2022. More UAT dates for outbound reporting from SDR will soon follow.

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PROD:
Credit - https://sdrws.cmegroup.com/sdrui-datacapture-ws/dataCaptureService/submitCSV/CDS
Interest Rate - https://sdrws.cmegroup.com/sdrui-datacapture-ws/dataCaptureService/submitCSV/IRS
FX - https://sdrws.cmegroup.com/sdrui-datacapture-ws/dataCaptureService/submitCSV/FX
Commodity - https://sdrws.cmegroup.com/sdrui-datacapture-ws/dataCaptureService/submitCSV/CMDTY
Equity - https://sdrws.cmegroup.com/sdrui-datacapture-ws/dataCaptureService/submitCSV/EQUITY
Collateral - https://sdrws.cmegroup.com/sdrui-datacapture-ws/dataCaptureService/submitCSV/COLL

Handling of Historical Data

Q.What is the meaning of the term “Historical Data” as it relates to the amended CFTC swap data reporting rules?
A. While not defined in the regulation, for these purposes, the term “Historical Data” shall mean any swaps/position which was submitted prior to Dec 5, 2022 (the “go-live” date).

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Q: What should I do if some or all of my open Historical Data cannot be “upgraded” to comply with CME SDRs then current Technical Specifications?
A: You will need to reach out to the Division of Data at the CFTC to inquire as to how you should handle the matter. 

Porting to/from another SDR

Q. Is porting from one SDR to another allowed? 
A. A reporting counterparty may change the swap data repository towhich swap transaction and pricing data is reported as set forth under §45.10 (d)

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