UPI Go Live for CFTC reporting
The pace of regulatory change globally has been frenetic and that continued into Q1 this year with the go live of UPI on 29 January for all asset classes ex commodities for CFTC reporting. UPI has been long discussed in the reg reporting space and all eyes were on its maiden implementation for CFTC ahead of upcoming implementation in EMIR and other jurisdictions later this year. The CFTC's approach also required reporting participants to update all open swaps and enrich with UPI on go-live date. This led to an increased burden not only to ensure accuracy and compliance with the regulation for new swaps but coupling that with the exercise to upgrade existing swap data.
Overall, the industry adoption to UPI went very well. Across Cappitech clients, UPI enrichment for open and new swaps was in the high 90% which is on par with the industry. As new regulations go live go, I think we can consider UPI a success. Onward to EMIR and the introduction of Commodity UPI!
Never one to rest on their laurels, the CFTC is also soliciting comments for feedback on amendments to part 43 and 45. Comments were initially due on 20 February, 2024 but the CFTC have extended the deadline to 11 April, 2024. Once comments have been reviewed and final rules published, the expectation is that go-live will be one year from that point. We are tentatively expecting that to be mid to late 2025.
While most of the amendments are centered around the introduction of Commodity UPI and certain masking of fields to protect anonymity, the CFTC are also exploring adding additional entity related fields among a handful or other economic field changes.
On 28 February, we welcomed several clients and industry peers to join us at our Navigating Trade Reporting Changes event in New York. We had representation from buy and sell side as well as industry experts to discuss topics ranging from the upcoming regulatory changes (EMIR, ASIC, MAS etc.) to challenges facing regulatory participants in adopting a wide range of regulatory changes over a short period of time. Resourcing and implementation were a key topic of discussion as well as digesting new upcoming regulations such as SEC 10c-1. We thank our guests for joining and providing engaging and enlightening discussion.
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