Lesson 01 · 5 min
Why Reporting Exists
The 2009 mandate, the repositories in the middle, and the five questions every report answers.
Nobody could see the market
September 2008. Lehman Brothers fails with hundreds of thousands of derivative contracts open, and nobody, not its counterparties and not its regulators, can quickly say who is exposed to whom. The contracts exist, but each one lives in two private books, and you know exactly what those private books look like. There is no shared record anyone can query.
September 2009, Pittsburgh. The G20 leaders commit, among other things, that OTC derivative contracts should be reported to trade repositories. One sentence of communique became a decade of local law: the CFTC's rules under Dodd-Frank went live first, at the end of 2012; the EU's EMIR reporting started in February 2014; Japan, Singapore, Australia, Hong Kong, Canada and others followed with regimes of their own. The mandate is global. The rulebooks are not.
One commitment, many rulebooks
Every major jurisdiction wrote its own law implementing the same G20 sentence. Scope, fields, formats, and deadlines all differ, and a single trade can be caught by several regimes at once.
A report follows the lifecycle
Reporting is not one filing at birth. Every lifecycle event, the unwind, the novation, each reset under some regimes, updates the record. The lifeline you drew is also a reporting obligation.
Who files depends on the regime
US rules are single-sided: one reporting counterparty, almost always the dealer. EMIR is dual-sided: both parties report, and the repository compares their answers, and what that comparison found gets its own lesson.
The identifiers you know carry it
LEI for who, UTI for which trade, and since 2024 the UPI for what product. Those three make reports joinable across firms and regimes, which is the whole point of collecting them.
What a report says
Strip a regulatory report to its core and it answers five questions: who traded (LEIs), which trade (the UTI), what product, how much, and when. Here is that minimum sketch for our running swap:
{ "uniqueTransactionIdentifier": "W22LROWP2IHZNBB6K528RT4K7Q20PXM3", "counterparty1": "W22LROWP2IHZNBB6K528", "counterparty2": "QW46WU5Y2RDY41BTIO66", "product": "InterestRate:IRSwap:FixedFloat", "notionalAmount": 10000000, "notionalCurrency": "USD", "effectiveDate": "2026-04-17", "expirationDate": "2031-04-17", "executionTimestamp": "2026-04-15T14:11:02Z"}
Who files, and when
Our swap makes the overlap concrete. Goldman Sachs International is a registered swap dealer, so the CFTC requires its side of the story: a public price tape entry within minutes, and a full regulatory report by the next day. The same entity is incorporated in London, so UK EMIR wants a report too, on its own field list and its own deadline. One trade, two rulebooks, neither aware of the other.
And the clock starts at execution, not at confirmation. The trade's birth drew the distinction precisely: executed on the 15th, formally bound on the 16th. The reporting deadline runs from the first of those moments, which is one of many details firms had to get right long before any paperwork settled.
UniqueSwapIdentifier.01What did the G20 commit to for OTC derivatives in 2009?