Recordkeeping and document retention
Recordkeeping and document retention in Energy, Power & Commodities is governed by a patchwork of overlapping mandates, with the U.S. Commodity Futures Trading Commission, the Federal Energy Regulatory Commission, and the U.K. Financial Conduct Authority each imposing distinct retention schedules, format requirements, and audit-access obligations that do not always align. FERC's recordkeeping rules under 18 C.F.R. Part 125 require physical and electronic records tied to wholesale market activity to be held for specific durations by specific entity types, and CFTC's Part 45 swap data obligations add a parallel layer for firms active in derivatives. Compliance teams in this sector are currently reconciling those requirements against cloud migration projects and third-party trading system contracts, where data custody questions carry direct enforcement exposure.
Watch
- CFTC Part 45 swap recordkeeping amendments: compliance deadlines vary by registrant category
- FERC audit staff requests for trading communications, including instant messages and voice logs
- U.K. FCA's retention overlap with EU REMIT for cross-border energy trading desks
- Cloud vendor contracts that transfer data custody away from the regulated entity itself
Recent material activity in Energy, Power & Commodities
Active monitoring in place across Energy, Power & Commodities. Material developments related to recordkeeping and document retention will appear here as they are published.