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6 July 2026CFTC and SEC joint request for comment

Swap and Security-Based Swap Data Reporting

Our response to the Commissions' joint request for comment (91 FR 37877). We respectfully suggest publishing the reporting framework itself as structured data: a machine-readable technical specification, executable validations with a public conformance corpus, an explicit lifecycle event model, governed reference data, and a uniform public dissemination dialect.

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