Reporting Trades Under Dodd-Frank
advancedPublished: 2026-01-01
Reporting Trades Under Dodd-Frank
The Dodd-Frank Act requires comprehensive reporting of swap transactions to swap data repositories (SDRs). This transparency initiative aims to provide regulators with a complete picture of derivatives market activity, systemic risk, and individual position concentrations.
Definition and Key Concepts
Reporting Hierarchy
Who reports:
| Counterparty Type | Reporting Obligation |
|---|---|
| Swap dealer (SD) | Reports all trades |
| Major swap participant (MSP) | Reports all trades |
| Financial entity | Reports if no SD/MSP |
| Non-financial end user | Reports if no SD/MSP/financial |
Determination rules:
| Trade Type | Reporting Party |
|---|---|
| SD vs. SD | Platform or determined by agreement |
| SD vs. MSP | Swap dealer |
| SD vs. financial | Swap dealer |
| SD vs. end user | Swap dealer |
| End user vs. end user | Agree by contract |
Report Types
| Report | Content | Timing |
|---|---|---|
| Creation | New trade details | Real-time (15 min) |
| Confirmation | Trade confirmation data | T+1 |
| Valuation | Current MTM value | Daily |
| Modification | Amendments, corrections | Real-time |
| Termination | Position closed | Real-time |
| State | Full position data | Daily |
Swap Data Repositories
| SDR | Products | Regulator |
|---|---|---|
| DTCC | All swaps | CFTC |
| ICE Trade Vault | All swaps | CFTC |
| CME Repository | All swaps | CFTC |
| Bloomberg SDR | All swaps | CFTC |
How It Works in Practice
Required Data Fields
Primary economic terms:
| Field | Description | Example |
|---|---|---|
| USI | Unique Swap Identifier | 1234567890ABCDEF |
| UPI | Unique Product Identifier | C-I-S-R-USD-SOFR-10Y |
| LEI | Legal Entity Identifier | 549300XXXXXXXXXXXX |
| Effective date | Start of swap | 2025-01-20 |
| Maturity date | End of swap | 2030-01-20 |
| Notional | Principal amount | $50,000,000 |
| Price | Fixed rate or spread | 4.25% |
| Execution timestamp | Time of execution | 2025-01-17T10:30:22Z |
Additional fields:
| Field | Purpose |
|---|---|
| Venue | Execution platform |
| Clearing indicator | Cleared or uncleared |
| Block trade indicator | Block or standard |
| End user exception | If applicable |
| Collateralization | CSA details |
Reporting Timeline
Real-time reporting (15 minutes):
- Trade creation
- Modifications
- Terminations
End-of-day reporting:
- Valuation data
- State data (positions)
Example timeline:
| Time | Event | Deadline |
|---|---|---|
| 10:30 AM | Trade executed | — |
| 10:45 AM | Real-time report due | 10:45 AM |
| 10:42 AM | Report submitted | Compliant |
| EOD | Valuation report due | Next morning |
| EOD | State report due | Next morning |
Message Formats
FpML (Financial products Markup Language): Standard format for OTC derivative messages.
Key message types:
| Message | Use |
|---|---|
| TradeNew | New trade report |
| TradeModify | Amendment |
| TradeCancelCorrect | Correction |
| TradeTerminate | Position closed |
| Valuation | Daily mark |
Worked Example
Reporting an Interest Rate Swap
Trade details:
- Counterparties: Bank A (SD) vs. Corporate B (end user)
- Product: 5Y USD IRS, pay fixed 4.50%, receive SOFR
- Notional: $75,000,000
- Trade date: January 17, 2025, 2:15 PM ET
- Venue: Bloomberg SEF
Reporting party: Bank A (swap dealer)
Step 1: Creation Report (Real-time)
| Field | Value |
|---|---|
| Message type | TradeNew |
| USI | BA20250117215900001 |
| Execution timestamp | 2025-01-17T14:15:00-05:00 |
| Reporting timestamp | 2025-01-17T14:20:00-05:00 |
| Counterparty 1 LEI | Bank A LEI |
| Counterparty 2 LEI | Corporate B LEI |
| Venue | Bloomberg SEF |
| Cleared | Yes |
| CCP | LCH |
Deadline: 2:30 PM ET Submitted: 2:20 PM ET (Compliant)
Step 2: Confirmation Report (T+1)
| Field | Value |
|---|---|
| Confirmation status | Confirmed |
| Confirmation timestamp | 2025-01-18T09:00:00-05:00 |
| Confirmation method | Electronic |
Step 3: Daily Valuation Report
| Date | MTM Value | Currency |
|---|---|---|
| Jan 17 | $125,000 | USD |
| Jan 20 | $180,000 | USD |
| Jan 21 | $95,000 | USD |
Margin Reporting
Under CFTC Margin Rules:
| Requirement | Threshold | Reporting |
|---|---|---|
| Initial margin | Posted/collected | Daily |
| Variation margin | Posted/collected | Daily |
| Collateral type | Cash, securities | Daily |
Example:
| Date | IM Posted | IM Collected | VM Posted | VM Collected |
|---|---|---|---|---|
| Jan 17 | $0 | $5M | $0 | $125K |
| Jan 20 | $0 | $5M | $0 | $180K |
Risks, Limitations, and Tradeoffs
Compliance Risks
| Risk | Consequence |
|---|---|
| Late reporting | CFTC enforcement, fines |
| Data errors | Correction required, potential penalty |
| Missing reports | Regulatory sanction |
| Wrong SDR | Must correct and re-report |
CFTC Enforcement
| Violation | Typical Penalty |
|---|---|
| Late reporting | Warning to $1M+ fine |
| Systematic failures | $1M - $50M+ |
| Data quality issues | Remediation orders |
| Willful violations | Enhanced penalties |
Common Pitfalls
| Pitfall | Description | Prevention |
|---|---|---|
| Wrong LEI | Counterparty not identified | LEI validation |
| Missing USI | Trade not uniquely identified | USI generation process |
| Stale data | Old valuation reported | Daily valuation process |
| Duplicate reports | Same trade reported twice | Reconciliation |
| Incorrect terminations | Position still open | Position management |
Data Quality Requirements
CFTC Data Quality Standards
| Standard | Requirement |
|---|---|
| Accuracy | Data must be correct |
| Completeness | All required fields |
| Timeliness | Within deadlines |
| Uniqueness | No duplicates |
| Consistency | Matching with counterparty |
Reconciliation Requirements
Counterparty reconciliation:
- Compare reported data with counterparty
- Resolve discrepancies within specified time
- Document reconciliation process
Portfolio reconciliation schedule:
| Counterparty Type | Frequency |
|---|---|
| With 500+ trades | Daily |
| With 51-499 trades | Weekly |
| With 50 or fewer | Quarterly |
Checklist and Next Steps
Reporting setup checklist:
- Register with SDR(s)
- Obtain LEIs for all entities
- Implement USI generation
- Configure reporting systems
- Establish valuation processes
- Test message connectivity
Daily operations checklist:
- Submit real-time reports within 15 minutes
- Generate end-of-day valuations
- Submit state reports
- Monitor for rejected messages
- Correct any errors
- Reconcile with counterparties
Quality control checklist:
- Validate data before submission
- Monitor rejection rates
- Track reporting timeliness
- Review error patterns
- Conduct periodic audits
- Update for regulatory changes
Related articles:
- For execution venues, see Swap Execution Facilities and Designated Contract Markets
- For EU requirements, see EMIR and MiFID Considerations for US Firms