Practice Areas

Swap Data Repositories (SDRs)

Swap Data Repositories (SDRs) are a new type of entity created by the Dodd-Frank Act in order to receive, store and disseminate swap data received from all counterparties, derivatives clearing organizations, designated contract markets, and swap execution facilities. The SDR’s purpose is to facilitate market transparency and price discovery by providing real-time access to swap trade information and serving as a repository for historical trading data.

The CFTC has also made SDRs responsible for collecting and storing data on so-called historical and transitional swaps, which were created after the rules where introduced, but before they were finalized. Compliance deadlines are contingent on the CFTC’s finalization of definitions governing “swap,” “swap dealer,” and “major swap participant.” Please contact Shipkevich attorneys for the latest information.


  • Guidance through the registration process;
  • Drafting data collection, retention and dissemination procedures that promote transparency and price discovery as required by the CFTC;
  • Compliance with changing requirements as the CFTC prepares to finalize the rules and definitions governing SDRs;
  • Ensuring that the client’s technology complies with relevant regulations, including the “real-time reporting,” “confirmation of data,” and “data privacy” requirements, and that all data is easily accessible to regulators;
  • Determining the circumstances under which the client has an obligation to comply with a foreign regulatory agency’s information request;
  • Keeping the client’s fee structure in line with CFTC rules;
  • Ensure that any commercial use of reported data is allowed under the rule.