Lesson 09 · 6 min

Where Reports Land

Trade repositories, swap data repositories, and the firms that run them between you and the regulator.

The box in the middle

Earlier lessons put a box between the firms and the regulators and called it a repository, made it the place where two sides of a trade meet and sometimes disagree, and had it validate an arriving report and answer with an acknowledgement or a reject. Time to open the box. A trade repository is a licensed entity whose whole job is to receive reports, check them, store them, reconcile the two sides of a dual-reported trade, and serve aggregated views to supervisors. Regulators do not take the reports directly; the repository is the buffer in front of them and the system of record behind them.

the repository sits between the firms and the supervisorGoldmanthe fundDTCC GTRthe largestRegis-TR · UnaVista · ICE Trade VaultCFTCUnited StatesESMA · FCAEU and UKreceives, validates, stores, reconcilesone role, three names: SDR, trade repository, security-based SDR

The name changes with the regime; the role does not. Under EMIR, in the EU and the UK, it is a trade repository, overseen by ESMA and the FCA. Under the CFTC it is a swap data repository, an SDR. Under the SEC, for security-based swaps, a security-based SDR. Our swap, reported by Goldman in the US and again under UK rules, lands in two of these at once, each licensed where its regime runs.

Who actually runs them

The field is small and concentrated. DTCC's Global Trade Repository is the clear leader: across the EU, UK, US, and Asian regimes it serves more reporting firms and takes in more reports than any peer, a lead ESMA has noted in its own supervision. The others are real but smaller: Regis-TR, a European venue; UnaVista, run by the London Stock Exchange Group; and ICE Trade Vault, run by the Intercontinental Exchange. A firm picks a repository per regime, and it has to be one licensed in that jurisdiction.

Key ideas
  • Receive, validate, store, reconcile

    Four jobs. The repository ingests the report, runs the regime's validations, the same-day reject lives here, keeps the record, and for dual-sided regimes pairs the two submissions on the UTI and matches their fields.

  • One role, three names

    Trade repository under EMIR, swap data repository under the CFTC, security-based SDR under the SEC. The vocabulary is regional; the function, a licensed system of record between firms and supervisors, is the same everywhere.

  • DTCC leads a small field

    DTCC's GTR carries the most firms and reports across jurisdictions; Regis-TR, UnaVista, and ICE Trade Vault make up most of the rest. Concentrated, because running a licensed repository in every regime is not a small undertaking.

  • Connectivity stays your problem

    The next lesson draws the line: shared rules fix the report's content, but the pipe to each repository, the formats it accepts, its file conventions, its onboarding, stay yours to build and keep running.

Accepted is not agreed

The repository answers twice, and the two answers mean different things. First it acknowledges a well-formed submission, or bounces a malformed one. Then, separately, it pairs the report with the other side by UTI and checks whether the fields agree. Here is that second verdict on the October cut, where one side booked the change a day late, the matching break from before:

{} the repository's answer (sketch)
{  "status": "ACK",  "uniqueTransactionIdentifier": "W22LROWP2IHZNBB6K528RT4K7Q20PXM3",  "receivedAt": "2026-10-15T14:02:47Z",  "pairing": "paired",  "matching": "unmatched: notional"}
An accepted report is not a reconciled one. The repository acknowledges a clean submission, then pairs it with the counterparty and compares the fields. Acceptance and agreement are two separate verdicts, and only the second one finds the break.
Try itOpen PartyIdentifierTypeEnum and TradeIdentifierTypeEnum in the explorer. The LEI and the UTI are what a repository pairs and aggregates on, and the model carries both as first-class identifier types, which is why a report built on the CDM arrives already speaking the repository's language.
◆ Checkpoint

01What is a trade repository's role?

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