​On November 1, 2019 NRECA, APPA and EEI jointly filed a comment letter with the CFTC on their swap data repository and reporting requirements NOPR.  Our comments relate primarily to nonfinancial commodity swaps in which end users are a counterparty.  We suggested the following:

• The Commission Should Streamline and Harmonize the Data Elements that Are Reported to SDRs Before Imposing Additional Reporting Requirements on Commercial End-Users.
  
• The Commission Should Not Impose On-Going Verification Requirements on Non-SD/MSP/DCO Reporting Counterparties.
  
• The Commission Should Delete the Requirement that Reporting Counterparties Agree with Non-Reporting Counterparties on Corrections to Previously-Reported Swap Data, Eliminate or Extend the New Timeframes for Non-SD/MSP/DCO Reporting Counterparties to Correct Errors and Omissions, and Delete the Language in the NOPR that Would Require Non-SD/MSP/DCO Reporting Counterparties To Correct or Complete Swap Data Reports for "Dead Swaps".
  
• The Commission Should Not Add Any Regulatory Reporting Obligations for Non-Reporting Counterparties.