Dodd-Frank lives on!
Ten years ago, the original Dodd-Frank trade reporting rules centered around just getting data over to a trade repository. It was a trade cleanup of epic proportions for many firms, however it wasn’t prescriptive in terms of fields required. Depending on the trade repository (TR) you chose, required fields differed enough that data from the TR’s couldn’t easily be aggregated.
Principles-based rules are great for legal frameworks, but they can leave data not “stackable,” like legos of all different shapes and sizes. Globally, CFTC and regulators are now on a two-phase mission towards standardization (so the pieces all fit).
This phase is all about the CFTC rewrite, with the goal of getting the same set of fields from each of the TRs. This in turn impacts the reporting requirements when submitting trades to the TRs.
As you may know, these changes went live on January 25, 2021 with a May 25, 2022 compliance date. The CFTC then issued a no-action letter, effectively delaying the go-live to Dec 5, 2022.
Keep in mind: Even if you’re using a vendor to support the technical changes, you’ll have to make determinations around your data and what values are submitted.
If you’re stressing about how to get all these fields to line up, download our helpful spreadsheet for mapping the new to old fields for ICE TV and CME TR.
CME changes are relatively contained given the smaller functional footprint of their TR.
Functional
- New fields required due to the CFTC rewrite (data analysis required).
Technical
- Error messages are now retrieved asynchronously (technical changes required).
- FAQs can be found here.
ICE changes make it easier to leverage multiple services through a single trade submission.
ICE has published a spreadsheet outlining data changes (download above).
Main Functional ICE Changes
- Fields required for a given product can easily be looked up using the Product Guide in the eConfirm web UI.
- Exotics are no longer supported as they don’t meet the data standards required by the CFTC
- If firms elect to have ICE create UTIs, ICE will use their LEI for the “UTI creator” as part of the UTI. For firms where Compliance teams determine their firms’ LEI’s need to be part of their trade UTIs, they will need to create their own UTIs.
Main Technical ICE Changes
Most firms need to simply submit trades and check status on submissions. For this majority, here are the two main points:
- ICE now has a single gateway for submitting trades to all services (eConfirm, TV CFTC, TV CA, TV EU, TV RRM). This is called the eConfirm Reporting Services (ECRS) Gateway.
- Overall status of the trade at each service can then be queried from single APIs (e.g. /api/reportingservice/query/trade/v1/listTradeStatusesByActivityDate)
- Errors from each service however, must be queried individually. The Central Failure Logs aren’t actually collecting all errors from the services.
ICE eConfirm/TradeVault has many other APIs firms can use to develop custom workflows.
- There are API level changes across the board described in the YAML files. Where there are conflicts between YAML and PDF guide, the YAML files govern.
- TV CFTC can be submitted to and polled independently of the ECRS Gateway.
- This is only available for Dealers, MSPs, SEFs, and DCOs.
- TV CFTC valuation and collateral can only be done directly to CFTC
- All other regime TRs are available via ECRS only
ICE also published a Best Practices Guide, accessible via login to their community portal. It outlines lots of technical issues to watch out for, like batching of data, how to manage cookies, not making simultaneous API calls, etc.
Much of this is standard practice and in other cases, the gotchas have largely been eliminated by virtue of this release.
ICE eConfirm/TradeVault has a recurring call with firms where participants can ask questions and hear challenges from peers as the industry prepares for this critical go-live on December 5th, 2022. To join the call, email ICE (eConfirmSupport@ice.com).
And just when you thought this was the last party for another decade…
Incorporation of common data elements will follow the ESMA refit.
Plus, the next phase will be about fully standardizing trade submissions to the ISO 20022 XML standard, likely for Q4 2023.
But no matter which regulations come out, Broadpeak will be right here, to help you solve your toughest data issues.
