CFTC Guidebook for Part 20 Reports (Large Trader Reporting)

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Gavel.png FINAL RULE: CFTC Final Rule: Large Trader Reporting Approved at CFTC Open Meeting, July 7, 2011
Timeline, Position Reports for Physical Commodity Swaps
Final Rule Effective Date No-action Relief Deadline
July 22, 2011 September 20, 2011 June 30, 2013

Derivatives clearing organizations and clearing members were required to begin reporting on cleared swaps on November 21, 2011, and to begin reporting on uncleared swaps on January 20, 2012. Additionally, the CFTC initially required fully compliant month-end open interest reports to be collected beginning in September 2011 through February 2012 and submitted to the Commission by March 20, 2012.

Temporary Relief, November 18, 2011

On November 18, 2011, the CFTC issued a press release announcing temporary relief for large traders until March 20, 2012. The relief is granted only for market participants who have been making a "good faith effort" to comply with the new rules, and is being provided to give an opportunity to transition to the CFTC's new XML-based large trader reporting system.[1]

No-Action Relief, March 20, 2012

On March 20, 2012, in light of concerns from market participants that they would not be fully compliant by the deadline, the CFTC Division of Market Oversight ("DMO") issued a letter establishing temporary and conditional no-action relief for less than fully compliant reporting under Part 20 until July 2, 2012. This no-action relief is subject to the same conditions as the November 18, 2011 safe harbor relief:

  • a good-faith attempt at compliance,
  • submission of month-end open interest reports that would allow the Commission to set position limits, and
  • the submission of an e-mail to the DMO.

Extension of No-Action Relief, July 18, 2012

On July 18, 2012, the CFTC issued temporary no-action relief for reporting by non-clearing member swap dealers under the CFTC’s large trader reporting requirements for physical commodity swaps and swaptions, in order to give non-clearing swap dealers time to transition into full compliance. The no-action relief is set to expire 60 days following the registration deadline for swap dealers. Additionally, the no-action letter will allow swap dealers under Part 20.10(e) an additional six months to comply. To be considered a 20.10(e) swap dealer, the person may not be an affiliate of a bank holding company and:

  1. Is not registered with the Commission as a futures commission merchant and is not an affiliate of a futures commission merchant;
  2. Is not registered with the Securities and Exchange Commission as a broker or dealer and is not an affiliate of a broker or dealer; and
  3. Is not supervised by any Federal prudential regulator. [2]

Part 20 Guidance

Data Dictionary The Guidebook includes a data dictionary for mapping data elements to a record layout, interim and final reporting formats and record layouts for the submission of reports and 102S filings, and multiple examples for converting and reporting swaps in futures equivalent units.[3] The guidebook was originally published in December 2011. An updated version, published May 31, 2012, can be found below.


  1. CFTC’s Division of Market Oversight Issues Letter to Market Participants Requiring Compliance with New Large Trader Reporting System for Physical Commodity Swaps and Swaptions. CFTC. Retrieved on November 22, 2011.
  2. Title 17: Commodity and Securities Exchanges. Code of Federal Regulations. Retrieved on July 18, 2012.
  3. CFTC’s Division of Market Oversight Issues Guidebook for Part 20 Reports. CFTC. Retrieved on December 7, 2011.

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