Comment Text:
With 87 FR 37839, Notice of Intent To Revise Collection 3038-0096 (Swap Data Recordkeeping and Reporting Requirements) and Collection 3038-0070 (Real-Time Public Reporting), CFTC invites comments 1.) on whether the proposed collection of information is necessary for the proper performance of the functions of the Commission, and 2.) on whether CFTC's estimate of the burden of the proposed collection of information is accurate.
Plus, the CFTC allows 3.) comments regarding ways to enhance the quality, usefulness, and clarity of the information to be collected and 4.) possible measures that can minimize the burden of collection of information on those who are to respond.
This comment is regarding how to enhance the quality, usefulness, and clarity of the information to be collected.
CFTC should strive for a maximum level of transparency when it comes to collecting, processing, monitoring, and publishing swaps-related information to be collected. It should provide maximum insight into the frequency of data errors and should provide a visual evaluation of the frequency of data errors that occur per its member organizations.
CFTC should especially make publicly available a) the asset classes to which the error (or errors) pertain and b) the number of transactions impacted by the error (or errors) in order to provide maximum insight into the order execution quality.
Within one hour of the error (or errors) occurring, CFTC must give a publicly available indication whether the issues underlying the error (or errors) produce new errors and must make publicly available any initial remediation plan for said error (or errors).
These measures are tantamount for the investing public and market participants.
Thank you for taking the time to read and process my comments. Your efforts are greatly appreciated.
-Wolfgang Potter-Bierhals
