CFTC Proposed Rule on Swap Data Recordkeeping and Reporting Requirements

On April 12, the CFTC proposed rules establishing swap data recordkeeping and reporting requirements for counterparties to swaps executed prior to enactment of the Dodd-Frank Act, and those executed after the Act but before the effective date for rules on swap recordkeeping and reporting. The proposed rules clarify what records must be kept and what data must be reported to swap data repositories, and would require limited recordkeeping for counterparties to historical swaps. For swaps in existence on or after the date of publication of the proposed rules, counterparties would be required to keep records of specified, minimum primary economic terms. The proposed rules would also make data concerning historical swaps available to regulators through swap data repositories beginning on the effective date for swap data reporting. CFTC Release.