The Commodity Futures Trading Commission (CFTC) finalized an order to sunset the routine position-reporting requirements under Part 20 of its regulations, permanently dismantling a legacy reporting framework. 

The move eliminates a duplicative data infrastructure mandate for buy-side firms, sell-side broker-dealers, and clearing organizations. 

“American financial market participants should not be saddled with costly and duplicative reporting requirements that do not improve the quality of our regulation,” CFTC Chairman Michael S. Selig said in a statement.

The Large Trader Reporting (LTR) rules under Part 20 were established in 2011 in the wake of the global financial crisis as part of the sweeping Dodd-Frank Act. The framework served as a data pipeline to give the commission immediate visibility into the physical commodity swap markets while a permanent, long-term regulatory reporting framework was built.

Importantly, the original rule included an explicit exit strategy. Section 20.9 provided a built-in sunset provision, stipulating that routine Part 20 reporting would phase out once alternative, robust data ecosystems were fully operational.

The maturation of the Swap Data Repository (SDR) framework – now governed by Parts 43, 45, and 49 – rendered Part 20 redundant. Because SDRs capture transaction-level swap data in real time, Part 20 was demanding overlapping data points from the same market participants. 

Recognizing the inefficiency, major trade organizations including the Futures Industry Association (FIA), the International Swaps and Derivatives Association (ISDA), and SIFMA had petitioned the commission to honor the Section 20.9 provision. 

Relief for Compliance

By rescinding the daily and event-based position reports, the CFTC provides tangible operational relief to swap dealers and clearing firms, as maintaining dedicated infrastructure to isolate, format, and push data into the separate Part 20 pipeline was a lift.

The regulatory relief will allow compliance and engineering teams to reallocate technology budget toward more critical risk management infrastructure and market structure optimization.

The CFTC says sunsetting of routine Part 20 filings does not signal a regulatory blind spot or a rollback in enforcement capability, and its ability to monitor the derivatives markets for manipulation or systemic concentration is uncompromised. 

Underlying recordkeeping mandates remain in force, and regulated entities must continue to track and maintain historical records of paired swap transactions, swaptions, and futures-equivalent calculation methods. Further, in the event of heightened market volatility, anomalous trading patterns, or targeted investigations, the regulator retains the power to compel firms to instantly produce its complete books and records.