CFTC Ends Routine Large-Trader Reporting for Physical Commodity Swaps

The Commodity Futures Trading Commission on Friday issued a final order ending routine large-trader reporting for physical commodity swaps, eliminating the daily and event-based filings required under Part 20 once the order is published in the Federal Register.

The change affects clearing organizations, clearing members and swap dealers that had been subject to the reporting regime. In practical terms, those firms will no longer have to submit the daily position reports and related identification filings that Part 20 had required for physical commodity swaps. The CFTC, which regulates U.S. derivatives markets, said it is keeping Part 20 recordkeeping requirements and its special-call authority in place as a transitional measure, preserving its ability to demand underlying books and records and request information such as futures-equivalency conversion methods when needed.

The agency said the routine reports had become largely duplicative of swap data it already receives through swap data repositories, or SDRs, under Parts 43, 45 and 49. It also said the quality and accessibility of that data have improved, including after technical specification changes implemented in January 2024. “American financial market participants should not be saddled with costly and duplicative reporting requirements that do not improve the quality of our regulation,” CFTC Chairman Michael S. Selig said in a press release. “This order relieves industry of a significant and unnecessary burden while ensuring the Commission retains full access to the position information it needs to protect these markets.”

The final order, issued under 17 CFR Section 20.9, says the routine reporting requirements of Part 20 for physical commodity swaps are now “ineffective and unenforceable.” The CFTC pointed to a prior agency and Office of Management and Budget estimate that the regime imposed $21,899,208 in recurring burden and capital costs. Industry groups had pressed for that outcome, including a petition from the Futures Industry Association on Sept. 22, 2025, and a joint letter from FIA, the International Swaps and Derivatives Association and the Securities Industry and Financial Markets Association on May 20, 2026.

Part 20 was adopted in 2011 as an interim large-trader reporting framework for physical commodity swaps while the broader post-Dodd-Frank swap reporting system was being built. The order says the rule included a built-in mechanism allowing the commission to end the routine reporting once SDR data became sufficient for market surveillance.

The CFTC also said the later rollout of its Part 150 position-limits framework reduced the need for separate routine Part 20 reporting. Even as the daily filings are set to end, the commission said it will continue to rely on existing recordkeeping obligations and special calls to obtain information directly from firms when necessary.

The voting summary in the order said, “On this matter, Chairman Selig voted in the affirmative. No Commissioner voted in the negative.” The order was issued in Washington on July 17 and signed by Robert Sidman, the commission’s deputy secretary. It takes effect upon publication in the Federal Register; the publication date was not provided.