External Meetings: Meeting with Reval

CFTC staff participated in a meeting with Reval discussing issues and questions related to the swap data repository (SDR) rulemaking.  The meeting covered two broad topics: (1) SDR registration; and (2) data aggregation and reporting, with an emphasis on the expected goals of SDRs such as data collection, transparency and systemic risk.~ ~SDR Registration~Reval believed that there should be separate repositories for collateral and collateral documentation, which are linked with transaction data.  Letters of credit or commitment letters should factor into determining whether a SDR has adequate financial resources to operate, especially for small to medium SDR entities.~ ~Data Aggregation and Reporting~Reval believes a "standardized grid" report format or "layers of aggregation" should be required to aid the Commission in aggregating market data for enforcement and systemic risk purposes.~ ~Counterparty Risk~Reval believes that the most important regulatory function of the SDR should be measuring counterparty risk, and therefore, suggested additional reporting fields, particularly, regarding valuation and collateral.