The Ultimate U.S. Swap Reporting Deadline Cheat Sheet

Weighing in at 200,000 words, the CFTC’s final rules governing the reporting of swaps data transactions isn’t the easiest collection of information to digest.  But like it or not, the documents are must-reads for many swaps market participants because they contain dozens of reporting compliance dates that will be phased-in over the course of the year.  Thankfully, now there’s an abridged version of the highlights.

Davis Polk’s Annette L. Nazareth and Gabriel D. Rosenberg were kind enough to do all of the heavy lifting and published the key dates in the March 2013 edition of Futures Industry magazine.  They were also good enough to make the summary table available to the readers of DerivAlert.

The table breaks out reporting deadlines for three types of reporting:

SDR Reporting – Under these requirements, swap counterparties must report a host of information about swaps to new swap data repositories that are registered with the CFTC. 

Real-Time Reporting – Under the real-time reporting requirements, key information about swaps must be publicly disseminated via swap data repositories. 

Historical Swap Reporting – Counterparties to historical swaps entered into before the compliance dates require reporting to swap data repositories are still required to report information to the repositories. 

Following is the complete breakdown:

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