CFTC Issues Extension of Time-Limited No-Action Relief Concerning Bespoke or Complex Swaps (Letter 13-35) (with Lofchie Comment)

The CFTC Division of Market Oversight ("DMO") issued a time-limited no-action letter granting relief for bespoke or complex swaps, from certain reporting obligations, under CFTC Rules Parts 43 ("Real-Time Public Reporting") and 45 ("Swap Data Recordkeeping and Reporting Requirements"). This letter extended a number of components from CFTC Letter 12-39, issued on November 20, 2012.

This letter recommends the DMO take no action against any reporting party for failure to report certain enumerated data fields otherwise required by Parts 43 or 45. Additionally, the letter provides no-action relief for complex swaps that are uncleared inter-affiliate swaps from certain confirmation data reporting obligations under Part 45.

The relief will expire on September 30, 2013.

Lofchie Comment: Please note comments related to the earlier version of this no-action letter, as linked here: "CFTC No-Action Relief Concerning Bespoke or Complex Swaps (with Lofchie Comment)" (November 30, 2012).

See: CFTC Letter 13-35.