FIX(ML)ing The Data Submission Standard: The CFTC's Large Trader Rules Get A Makeover

Part 17 of the CFTC's regulations require futures commission merchants, clearing members of registered derivatives clearing organizations, and foreign brokers holding omnibus accounts with such FCM clearing members to submit reports of the positions held by "large traders" (traders controlling positions exceeding thresholds prescribed under those regulations). For reporting firms, large trader reporting presents perhaps the most stubborn compliance challenge in the CFTC rulebook.

Part 17's difficulties have stemmed in large part from having to conform position reporting to the strictures of a Cobol-based data submission standard originally developed in the 1980s. (In truth, the larger challenge derives from the CFTC's unwillingness to adopt a "report all" standard for position reporting — the easiest to implement for reporting firms and presumably the one most consistent with complete transparency to the regulator. But that fight's for another day.)