CFTC Swap Reporting Rewrite

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Treliant Takeaway:

Treliant helps global banking institutions manage the transition to new swap reporting rules as required by the CFTC Rewrite.  The Rewrite has required firms to transition to a new technical specification whilst dealing with new requirements for data completeness and accuracy within a short timeframe from May 25, 2022 up until December 5, 2022. Our consultant team has deep experience helping our global banking clients prepare for and manage the complexity of regulatory change.


As of December 5, 2022 firms should be live with the CTC Rewrite. However, the short implementation timeline means firms are still considering the best approach to Operating Models and Controls which now need to be established to maintain the data and reporting requirements.  Firms are also looking for support to find solutions and prepare for future rewrites.

Future Rewrite Examples Include:

  • Unique Product Identifier (UPI): due to come into effect in the EU in April 2024 with other jurisdictions expected to follow
  • ISO 20022 XML: start date of March 2023 for early adopters and a 3-year grace period for other firms to adopt at their own pace