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Comment for General CFTC CFTC and SEC Staff Public Roundtable on International Issues relating to Dodd-Frank Title VII

  • From: Michael Denkeler
    SunGard InTrader

    Comment No: 48120
    Date: 8/30/2011

    Comment Text:

    Hello. I have a few questions.

    1. Have Technical specifications been written and published for the CFTC Proposed Rules for Real-Time Public Reporting?

    Appendix A to Part 43—Data Fields for Real-Time Public Reporting contains information on some of the required fields along with a brief description of each, but does not contain enough information. I am in need of a technical description of each field along with detail of all field choices, lengths and formats. I also need to know the file layout requirements, transmission requirements, etc.

    Please advise if a technical specification has been published and where I may find a copy or when a technical specification will be available.

    Also, if the technical requirements are up the individual Swap Data Repository’s (SDR), how will data integrity be maintained across organizations?

    2. Is there a list of Swap Data Repository (SDR) participants?

    3. Is there a list of Designated Contract Markets (DCM)?

    4. Is there a list of Swap Execution Facilities (SEF)?

    5. The proposed implementation date was previously January 2012. Due to the recent 15 month delay of the Dodd-Frank Act, will the January 2012 implementation date move by 15 months?


    Michael Denkeler Business Analyst Consultant, Product Management SunGard Capital Markets (Position, Risk & Operations) Stream InTrader Tel 817-431-1907 Cell 972-877-5805

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