FIA responds to CFTC proposed rule on Part 17 Large Trader Reporting

28 August 2023

FIA has submitted a response to the Commodity Futures Trading Commission’s Large Trader Reporting Requirements Notice of Proposed Rulemaking and accompanying Guidebook.

Overall, FIA supports the CFTC’s efforts to modernize the large trader reporting process and transition from the 80-byte reporting format to a FIXML reporting format. However, there remain outstanding issues that the CFTC should address to accomplish the goal of modernizing its reporting rules in a way that promotes transparency and quality of data. For instance, reporting firms, particularly smaller firms and foreign brokers, need additional clarity, in writing, on the types of data to report for certain data elements.

In addition, the CFTC should obtain static data from one centralized source (i.e., the relevant exchange) rather than requiring each reporting firm to submit the same data. FIA has identified seven data elements that constitute static data that the CFTC should obtain from the exchanges, not reporting firms.

Read FIA’s full response and list of recommendations here.

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