Published on November 10 by the Canadian Securities Administrators (CSA), the Guidance provides guidance to market participants regarding the changes to swap data reporting rules.

The proposal to revise the current Trade Reporting Rules (Proposed Amendments) was first released for comment on June 9, 2022, see our article here. While the proposed amendments are scheduled to be finalized in 2024, the CFTC review of the U.S. swap data reporting rules will come into effect on December 5, 2025.

Thus, to address the fact that there will be a transition period during which certain reporting counterparties will be subject to revised reporting requirements under the CFTC amendments but will not be subject to CSA Proposed Amendments until they are finalized, the CSA’s guidance covers:

• Cases where derivatives data is reportable under the current Trade Reporting Rules, and where analogous data is required under the CFTC Proposed Amendments.

• Cases where derivatives data is reportable under the CFTC Proposed Amendments but is not reportable under the current Trade Reporting Rules.

• Where derivatives data is reportable under the current Trade Reporting Rules, but is not reportable under the CFTC Proposes Amendments.

This Guidance will be of interest for entities that report under existing Canadian trade reporting rules as well as the United States swap data reporting rules.