ARTICLE
22 June 2015

US Commodity Futures Trading Commission's Division Of Market Oversight Extends Time-Limited, No-Action Relief For Swap Dealers And Major Swap Participants From Compliance With Reporting Obligations

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A&O Shearman

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According to the no-action letter, the DMO will not recommend that the CFTC take enforcement action against an SD or MSP for failing to comply with the requirements of the CFTC's regulation to report valuation data.
United States Finance and Banking

On June 5, 2015, the US Commodity Futures Trading Commission's Division of Market Oversight issued a no-action letter (CFTC Staff Letter 15-38) extending time-limited relief to Swap Dealers and Major Swap Participants from the obligation to report valuation data for cleared swaps. The no-action relief applies to (i) all SDs and MSPs that are reporting counterparties under regulation 45.8, for the purposes of section 45.4(b)(2)(ii) of the CFTC's regulations, and (ii) all cleared swaps for which the SD or MSP has the obligation to report valuation data under section 45.4(b)(2)(ii). According to the no-action letter, the DMO will not recommend that the CFTC take enforcement action against an SD or MSP for failing to comply with the requirements of the CFTC's regulation to report valuation data.

Originally expiring on June 30, 2015, in accordance with the time-limited relief provided previously in CFTC Staff Letter 14-90, the no-action letter issued on June 15, 2015, extends the relief until June 30, 2016.

The press release is available at: http://www.cftc.gov/PressRoom/PressReleases/pr7186-15#PrRoWMBL

CFTC Staff Letter 15-38 is available at: http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/15-38.pdf and CFTC Staff Letter 14-90 is available at: http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14-90.pdf.

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