On 18 June 2026, the United States Securities and Exchange Commission and the United States Commodity Futures Trading Commission jointly issued a Request for Comment titled Joint Request for Comment on Swap and Security Based Swap Data Reporting. The consultation seeks industry feedback on potential reforms to the reporting frameworks governing swaps and security based swaps under Title VII of the United States Dodd Frank Act. The agencies are evaluating whether existing reporting obligations should be harmonised, simplified and modernised to improve data quality, reduce operational complexity and enhance regulatory oversight. The initiative reflects a broader effort by both regulators to streamline compliance obligations while ensuring that reported transaction data remains accurate, useful and aligned with evolving market practices and technological developments.
SEC and CFTC Launch Review of Swap Data Reporting Frameworks
The Request for Comment examines whether changes to the design, scope and structure of swap and security based swap reporting requirements could improve consistency between the two regulatory regimes. The agencies stated that market participants now possess more than a decade of experience operating under the reporting framework introduced by Title VII of the Dodd Frank Act. This experience, combined with technological developments and evolving market structures, has prompted a review of whether current reporting requirements remain appropriately calibrated. According to the regulators, the consultation aims to identify opportunities to improve market transparency, strengthen regulatory oversight and reduce unnecessary reporting burdens while preserving the distinct statutory responsibilities of each agency.
Joint Request for Comment on Swap and Security Based Swap Data Reporting
The consultation is formally titled Joint Request for Comment on Swap and Security Based Swap Data Reporting.
The agencies are seeking public input across five principal areas:
- Harmonisation across reporting frameworks.
- Transparency and data quality.
- Operational complexity.
- Standardised identifiers and reference data.
- Implementation considerations. The review covers both swap reporting to Swap Data Repositories and security based swap reporting to Security Based Swap Data Repositories.
Regulators Examine Data Quality and Reporting Burdens
A central theme of the consultation is whether current reporting obligations have become unnecessarily complex.
The agencies acknowledge that reporting frameworks collecting large volumes of information may not necessarily improve regulatory oversight if the resulting data lacks consistency, accuracy or practical utility. They note that reporting requirements may have unintentionally contributed to issues relating to data completeness, timeliness and integrity.
The Request for Comment specifically notes that the Commodity Futures Trading Commission currently requires reporting of up to 128 data elements, while the Securities and Exchange Commission’s reporting framework generally remains narrower in scope. The agencies are seeking views on whether certain data elements should be consolidated, simplified or removed.
Greater Harmonisation Between SEC and CFTC Frameworks Under Consideration
The consultation places considerable emphasis on alignment between the two reporting regimes. The agencies seek feedback on whether reporting obligations, technical specifications and data standards should be further harmonised to reduce duplicative compliance burdens for firms active in both swap and security based swap markets. Among the questions posed, the Securities and Exchange Commission asks whether it should amend Regulation SBSR to align more closely with the Commodity Futures Trading Commission's reporting framework and whether the SEC should ultimately adopt technical reporting specifications substantially similar to those used by the Commodity Futures Trading Commission.
Blockchain Based Swap Transactions Included in Consultation
The agencies have also requested feedback on reporting requirements for transactions that may occur on blockchain infrastructure. Specifically, the Request for Comment asks whether amendments or additional guidance may be required where swaps or security based swaps are executed, recorded or processed through blockchain based systems and whether such transactions should be subject to different reporting requirements. This represents one of the clearest acknowledgements within the consultation that emerging financial infrastructure may warrant further regulatory consideration.
Standardised Identifiers and Reference Data Under Review
The consultation also examines the use of standardised identifiers used throughout derivatives reporting frameworks.
The agencies seek feedback regarding:
- Unique Product Identifiers.
- Legal Entity Identifiers.
- Product classification systems.
- Reference data structures.
- Alternative identification standards.
The regulators are evaluating whether additional information currently reported on a transaction by transaction basis could instead be maintained through static reference data frameworks.
Alternative Approaches to Reporting and Oversight
The Request for Comment also asks whether operational complexity associated with lifecycle event reporting, validation rules and error correction obligations could be reduced. The agencies seek views on introducing materiality thresholds for reporting corrections, machine readable rule structures, standardised reporting logic and potential revisions to reporting hierarchies that determine which counterparty bears reporting responsibility. The consultation further examines whether current public dissemination practices continue to support transparency and price discovery objectives while balancing confidentiality and market liquidity concerns.
Statements from SEC and CFTC Leadership
SEC Chairman Paul S. Atkins stated:
“Extensive data collection, if not appropriately calibrated, can hinder, rather than enhance, understanding and accountability. Working closely with the CFTC, we can ensure that we are collecting the data necessary to meet statutory objectives under a harmonized reporting regime.”
CFTC Chairman Michael S. Selig stated:
“I’m proud to be working alongside SEC Chairman Atkins to streamline and harmonize swap data reporting for registrants in accordance with our ongoing efforts to foster interagency cooperation. I look forward to hearing from market participants about the ways we can cut red tape and reduce costs, while still collecting the data we need to conduct our market oversight responsibilities.”
Regulatory Significance
The consultation represents a substantial review of the reporting architecture established under Title VII of the Dodd Frank Act. While the initiative does not propose specific rule amendments, it signals a regulatory shift towards simplifying reporting obligations, improving data quality and strengthening coordination between the Securities and Exchange Commission and Commodity Futures Trading Commission.
For swap dealers, security based swap dealers, data repositories, financial institutions and technology providers, the consultation may shape the next phase of derivatives reporting regulation in the United States. Areas such as data harmonisation, blockchain based reporting, standardised identifiers and reporting simplification are likely to remain central themes as both agencies consider future reforms.
Comments on the Joint Request for Comment on Swap and Security Based Swap Data Reporting must be submitted within 60 days following publication in the Federal Register. The United States Securities and Exchange Commission and Commodity Futures Trading Commission have encouraged stakeholders to provide data driven submissions addressing compliance costs, operational challenges, reporting quality and implementation considerations. To submit comments.
