CFTC Staff Extends Financial Reporting Relief for Bank Swap Dealers

CFTC staff extended temporary no-action relief for bank swap dealers ("Bank SDs") from certain financial reporting requirements.

CFTC Letter 23-11 extended relief previously granted in Letter 21-18 (that was scheduled to expire on October 6, 2023) until the earlier of either October 6, 2025 or the adoption of revised financial reporting and notification requirements for Bank SDs. The CFTC provided the relief in response to a request for the extension based on "significant operational challenges" that certain financial reporting rules would have on Bank SDs should the relief expire.

As previously covered, the CFTC initially provided the relief, in response to a request from SIFMA and ISDA, from financial reporting requirements under CFTC Rule 23.105(p)(2) ("Financial recordkeeping, reporting and notification requirements for swap dealers and major swap participants") and information otherwise required to be submitted on CFTC Appendix C to Subpart E of Part 23.