The Commodity Futures Trading Commission proposed to amend certain of its rules regarding recordkeeping and reporting requirements for cleared swaps. These rules were adopted in December 2011 as part of the Commission’s implementation of parts of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Among other things, the proposed rules address obligations of the different parties when a swap is initially entered into bilaterally and subsequently cleared by a derivatives clearing organization. The proposed amendments address creation, confirmation and continuation data reporting requirements, among other matters. The CFTC also proposed to codify certain no-action letters to eliminate the requirement for swap dealers and major swap participants to report data valuation data for cleared swaps. According to CFTC Chairman Timothy Massad, if adopted, the proposed amendments “will improve data quality and reduce compliance costs, by clarifying and simplifying some requirements and eliminating unnecessary obligations.” Commissioner J. Christopher Giancarlo supported the proposed reporting amendments but suggested that the CFTC “take the same approach with other rule sets, including several of its swaps trading rules, to optimize the CFTC’s swaps regulatory framework.” Comments will be due by 60 days after publication of the proposed amended rules in theFederal Register. (Click here for further information on the CFTC proposal in the article “CFTC Proposes Cleared Swap Reporting Amendments” in the August 21, 2015 edition of Corporate & Financial Weekly Digest by Katten Muchin Rosenman LLP.)