Derivatives

Trade Report Analysis — Self-Reported & Alleged

CFTC Parts 43, 45 & 46

Ingestion and analysis of both the swap dealer's own submitted reports and alleged trade reports (counterparty-submitted records) at the swap data repository (SDR), across all five CFTC asset classes. This dual-sided review identifies not only gaps or errors in the firm's own reporting, but also mismatches, duplicates, and unconfirmed positions arising from counterparty-alleged trades — the type of issue that can cause the same transaction to appear twice at the SDR under different identifiers.

• Foreign Exchange (FX)
• Interest Rate (IR)
• Commodity (CO)
• Credit (CR)
• Equity (EQ)

SEC Regulation SBSR Reporting Review

Security-Based Swaps · 17 C.F.R. §§ 242.900–242.909

The same dual-sided (self-reported and alleged) analysis extended to SEC-regulated security-based swaps — single-name and narrow-based (nine or fewer component) equity and credit instruments, including single-name and narrow-based index credit default swaps — benchmarked against Regulation SBSR requirements, including reporting obligations (§901), public dissemination (§902), and error correction (§905).

Field-Level & Gap Analysis

Three regulatory pillars

Comprehensive review of reporting output against the three regulatory pillars:

Completeness

Are all required fields and transactions being reported?

Accuracy

Is the reported data correct and consistent with the underlying transaction?

Timeliness

Is data reported within required regulatory windows?

Swap Dealer / MSP Registration & De Minimis Threshold Analysis

17 C.F.R. Part 23

Assessment of aggregate notional calculations and reporting practices that could affect Swap Dealer or Major Swap Participant registration status, including identification of underreported or miscalculated trade populations that may distort de minimis threshold calculations.