CFTC sunsets Part 20 routine large-trader reporting for physical commodity swaps
Clearing organizations, clearing members and swap dealers must keep Part 20 swap records for CFTC special call even after routine position reporting ends
Change
On 17 July 2026 the CFTC issued a final order sunsetting the routine daily and event-based position-reporting requirements of Part 20 for physical commodity swaps, relieving clearing organizations, clearing members, and swap dealers of those filings. The recordkeeping and special-call provisions of Part 20 are retained: reporting entities must keep paired swap and swaption records and futures-equivalent conversion methods and produce them on an appropriately scoped special call. The order is effective on publication in the Federal Register.
Why it matters
The CFTC is moving routine access to position data off daily Part 20 filings and onto its retained special-call authority and the broader swap-data reporting framework in Parts 43, 45, 49 and 150. Although the routine reporting obligation ends, clearing organizations, clearing members, and swap dealers remain bound to maintain records of paired swap and swaption transactions and futures-equivalent conversion methods and to furnish them when served with an appropriately scoped special call. Entities that decommission Part 20 recordkeeping on the basis of the sunset would be exposed on a subsequent special call.
Implications
- — Clearing organizations, clearing members and swap dealers must continue to maintain records of paired swap and swaption transactions and of futures-equivalent conversion methods and be able to produce them on an appropriately scoped CFTC special call, because the sunset removes only the routine filing obligation and leaves the Part 20 recordkeeping and special-call provisions in force.
- — Reporting entities decommissioning Part 20 processes must preserve the retained recordkeeping and special-call capability rather than retire it wholesale, because treating the sunset as a full repeal would leave them unable to respond to a special call and in breach of the retained provisions.
Who is affected
- — Clearing organizations reporting physical-commodity swap positions
- — Clearing members filing on behalf of market participants
- — Swap dealers subject to Part 20
What to watch
- — Publication of the final order in the Federal Register, on which the sunset and the retained recordkeeping/special-call transitional measure take effect.