CFTC Overhauls Swaps Reporting Rules

On September 17, 2020, the Commodity Futures Trading Commission ("CFTC") unanimously approved three final rules¹ to overhaul its regulations for real-time public reporting, swap data reporting, and data validation, verification, and correction (collectively, "Final Rules").² Key highlights of the Final Rules include:

Real-Time Public Reporting

• Block Trade Dissemination Delays. Contrary to a proposal to adopt a single block trade public dissemination delay of 48 hours after execution, the CFTC retained the existing delays, which for most transactions range from 15 minutes to 2 hours after execution, depending on the transaction type.
• Adjustment to Minimum Block Sizes and Notional Cap Sizes. Consistent with its proposal and provisions of its existing rules that it had not previously implemented, the CFTC will adjust its minimum block sizes (above which a trade is eligible for a public dissemination delay and an exception from certain trade execution