CFTC – Interim Final Rule & Request for Comment – Portfolio Reconciliation Requirements for Swap Dealers and Major Swap Participants-Revision of “Material Terms” Definition

January 5, 2021 – CFTC interim final rule to avoid disruption in portfolio reconciliation for SDs and MSPs. The objective is to move the current language to a different part of commission regulations, so that market participants can continue portfolio reconciliation in a current manner.

Organizational Language Change

September 2020 Final Rule for swap data repositories (SDR rule) made substantial changes to 17 CFR 45 appendix I, omits the concept of primary economic terms, deletes data fields. Regulation 17 CFR 23 on portfolio reconciliation leverages terminology, material terms, whose definition itself relies on primary economic terms concept defined in part 45. The interim rule moves current part 45 appendix I language to part 23 to retain definition technicalities between the two terms and avoid procedure modification for SDs, and MSPs.


Interim final rule effective January 5, 2021, with comments due on or before March 8, 2021.

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