Regulatory changes

The FDTA data standards are final, and nothing changes in your reports yet

Nine agencies have finalised joint data standards under the Financial Data Transparency Act, effective 1 October 2026. The rule adopts identifiers such as the LEI but changes no reporting requirement on its own; each agency must act within two years.

The applicable.ai team4 min read

The Financial Data Transparency Act told the financial regulators to agree on common data standards for the information they collect. Almost two years after the August 2024 proposal, the joint rule is final. It was published on 25 June 2026 (91 FR 38246) by nine agencies: the OCC, the Federal Reserve Board, the FDIC, the NCUA, the CFPB, FHFA, the CFTC, the SEC and Treasury.

The rule takes effect on 1 October 2026. The notice gives the main point right after the date: "At the effective date, the joint rule will not change any reporting requirements without further action by the agencies."

What was adopted

The rule sets one standard for each kind of data:

DataStandard
Legal entitiesISO 17442, the Legal Entity Identifier (LEI)
Swaps and security-based swapsISO 4914, the Unique Product Identifier
Other financial instruments (classification)ISO 10962, the CFI code
DatesISO 8601
States, possessions and directionalsU.S. Postal Service abbreviations
Countries and subdivisionsGENC codes
CurrenciesISO 4217

For data transmission and schema formats the agencies didn't pick a single format. They set properties a format has to have, including being "nonproprietary or available under an open license."

A few things changed from the proposal. The agencies dropped FIGI as a joint standard. They said the CFI code is for classifying, not identifying, instruments that aren't swaps. They adopted ISO 8601 for dates without referring to its Basic format option. And they said more plainly that each agency may tailor the standards, or use standards that aren't in the joint rule.

The rule amends 12 CFR parts 15, 262, 304, 753, 1077 and 1226, 17 CFR parts 140 and 256, and 31 CFR part 151.

What it doesn't do

It doesn't require your institution to get an LEI, or anything else. The notice says the final joint rule "does not mandate the use of any specific standard or impose any changes to collections of information," and that the standards "do not create or change existing reporting, recordkeeping, or other obligations of any person or entity."

The obligations will come later, from each agency. Under the FDTA, each agency's own standards "must take effect not later than two years after the final joint rule is promulgated." The agencies with that job are the OCC, the Federal Reserve Board, the FDIC, the NCUA, the CFPB, FHFA and the SEC. The joint rule also says "scaling considerations for small entities and local governments will be addressed" in those agency rulemakings, not here.

What it could mean

We see nothing to do this quarter, and we'd resist anyone selling a project around it. The joint rule is a menu. The bill arrives when the FDIC, OCC, Fed or NCUA write their own rules for call reports and other filings, and those are where a small bank or credit union should spend its comment energy.

The LEI is the item to watch. Some institutions will already have one for other reasons; many smaller banks and credit unions probably don't. If an agency later requires an LEI on a routine filing, getting one shouldn't be hard, but it becomes one more piece of reference data somebody has to own and keep current. Our guess is that agencies will want LEIs on regulated entities first, and much less likely on borrowers or small business customers, but the joint rule doesn't decide that.

The other point worth flagging to your core provider is the date format. ISO 8601 is close to what most systems already produce, so we wouldn't expect much trouble there. Data transmission is a bigger unknown. The agencies chose open, nonproprietary formats in principle, and the cost to a small institution will depend on how much of that its vendors absorb.

We think the two-year clock matters more than the October date. If the agencies take the full two years, their own rules will land close to mid-2028, with proposals some months before that. That's when to read closely and comment, especially on how far the agencies scale requirements down for smaller filers.

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