Comment Text:
On November 6, 2023, the CFTC's Global Markets Advisory Committee advanced the attached recommendation on streamlining a proposed increase in data elements reportable to swap data repositories. Swaps dealers completed an extensive update to their reporting requirements for December 2023 with most of the additional fields and changes derived from the CPMI-IOSCO Critical Data Elements (CDE). This proposal would add an additional 49 fields to the 128 data elements already required, 30 of which are CFTC-specific, taking the CFTC away from the intention of the CDE to drive more harmonized and consistent data reports which would be capable of being aggregated and analyzed across borders to better understand global risk.
