CFTC No-Action Relief Concerning Terms That May Be Excluded from Portfolio Reconciliation; Applies to All SDs and MSPs (Letter 13-31) (with Lofchie Comment)

The CFTC's Division of Swap Dealer and Intermediary Oversight ("DSIO") issued the attached no-action letter which relates to the terms that are included in portfolio reconciliations.

CFTC Rule 23.502 requires that swap counterparties engage in portfolio reconciliation (or provide opportunities for portfolio reconciliation) at regular intervals. This no-action relief identifies 11 data fields that may be excluded from such portfolio reconciliations; i.e., terms that the parties do not have to confirm are matched.

Lofchie Comment: The available relief relates to conditions that are irrelevant to the purposes of the reconciliation, such as the times at which the trade was originally executed or submitted to a swap data repository.

See: CFTC Letter 13-31.