The WFE welcomes the opportunity to comment on the notice of proposed rulemaking published by the Commodity Futures Trading Commission (CFTC) to amend the reporting and information regulations applicable to derivatives clearing organizations (DCOs, otherwise known as CCPs).
In general, the WFE encourages further scrutiny of reporting standards. As noted in our recent paper on Cyber Incident Reporting (CIR), WFE members have commented on these matters before. It is important to note that any reviews of reporting standards must be practical, and not counterproductive to the reporting of actual, material incidents and threats. In this situation, it is the WFE’s view that the proposed amendment to the CFTC’s reporting and information regulations do not meet this requirement. Specific Comments (below) highlight our concerns with the current draft of the proposal.