About a-team Marketing Services
The knowledge platform for the financial technology industry
The knowledge platform for the financial technology industry

A-Team Insight Blogs

Goldman’s Perry Highlights Instrument Data Challenges of the OTC Derivatives Reforms Within Dodd Frank

Subscribe to our newsletter

The reform of the OTC derivatives markets as part of the US Dodd Frank Act will likely cause a whole heap of instrument identification challenges, according to Jim Perry, vice president of product data quality at Goldman Sachs. Speaking at last week’s FIMA conference in London, Perry indicated that the central clearing of these products would require the development of new standard instrument identifiers for structured products such as swaps, as well as entity identifiers.

“We need to determine how to represent a swap, for example, within trade management and client reporting systems,” he elaborated. Perry sits within the operations department at the investment bank and is therefore currently helping to prepare Goldman for the changes involved in the regulatory reform process, including dealing with these identification challenges.

The identification of underlying entities involved in credit default swaps (CDSs) and similar structured derivatives could also pose a problem, he added. “There is no universally accepted legal entity identifier across the market, so it will be a challenge to determine what to use to identify the institutions related to credit derivatives,” Perry explained.

This concern about the lack of an entity identifier was a common theme throughout the conference, in the face of developments such as the Office of Financial Research and greater regulatory attention on the standardisation challenge. Perry noted that the direction that the US moves in would likely determine what happens in the rest of the world with regards to both instrument and entity identifiers.

The regulatory community is also seemingly apprised of the challenges and potential costs involved in introducing a new set of identifiers and is keen for feedback from the industry. The Commodity Futures Trading Commission (CFTC) commissioner Scott O’Malia commented during a testimony this month: “One important element of this proposed rule is the requirement to establish a unique identifier for every swap, swap transaction, and swap participant. I am eager to receive comment on this provision. While I believe the policy rationale underlying this requirement is sound, I do recognise that the cost burden of such an ID is high and its impact on data storage demands is significant. However, I understand that the domestic and international communities are eager to adopt such a concept and there is no better time to implement such a rule than at the beginning.”

O’Malia noted that the data standardisation challenges underlying the swaps markets will not be simple to solve and suggested that the 75 requests for comment the CFTC has made so far is the “appropriate” approach. He has called for an extension to the current deadline for comments in order to allow the industry to properly assess the 75 proposals.

The industry may also be facing the prospect of two data utilities rather than one – a market data utility as well as the Office of Financial Research’s reference data utility – as part of the proposals made by O’Malia. He described his “strong desire” to reorganise the CFTC’s Office of Information and Technology Services in order to establish an Office of Market Data Collection and Analysis. “This entity will clarify the commission’s technology needs and support the various divisions’ market surveillance requirements,” he said. Let’s hope this one won’t cost another US$500 million to operate…

You can read O’Malia’s full speech here.

Subscribe to our newsletter

Related content

WEBINAR

Recorded Webinar: Best practice approaches to data management for regulatory reporting

Effective regulatory reporting requires firms to manage vast amounts of data across multiple systems, regions, and regulatory jurisdictions. With increasing scrutiny from regulators and the rising complexity of financial instruments, the need for a streamlined and strategic approach to data management has never been greater. Financial institutions must ensure accuracy, consistency, and timeliness in their...

BLOG

EU’s AI Act Loads Data Responsibilities on Institutions but also Offers Opportunities

Financial institutions are under pressure to put their data estates in order as the European Union’s artificial intelligence regulation comes into force this week, threatening huge fines for failures to observe its tough rules on the safe and fair use of the technology. Nevertheless, the introduction of stringent measures that will place new compliance burdens...

EVENT

Data Management Summit London

Now in its 16th year, the Data Management Summit (DMS) in London brings together the European capital markets enterprise data management community, to explore how data strategy is evolving to drive business outcomes and speed to market in changing times.

GUIDE

Regulatory Data Handbook 2025 – Thirteenth Edition

Welcome to the thirteenth edition of A-Team Group’s Regulatory Data Handbook, a unique and practical guide to capital markets regulation, regulatory change, and the data and data management requirements of compliance across Europe, the UK, US and Asia-Pacific. This year’s edition lands at a moment of accelerating regulatory divergence and intensifying data focused supervision. Inside,...