CFTC Changes Part 43 and Part 45 of the Reporting Fields for Certain Commodity Swaps (with Pantano Comment)

According to correspondence between the CFTC, CIO and ICE Trade Vault, the CFTC has changed parts of the reporting fields for other commodity swaps, including Part 43 ("Real-Time Public Reporting") and Part 45 ("Swap Data Recordkeeping and Reporting Requirements").

Pantano Comment: These changes, should they go into effect, will require substantial IT systems and upgrades. Firms may wish to consider commenting to the CFTC that the changes should not be effective absent a formal rulemaking process, including publication of the proposed changes in the Federal Register and an opportunity to comment. Interested persons may contact Mr. Pantano.

See: ICE Trade Vault's Letter to John Roberts; John Roberts' Response Letter to ICE Trade Vault; CFTC John Rogers Exhibit Table.