CFTC Provides Swap Dealers Reporting Relief for Equity and Foreign Exchange Swaps (with Lofchie Comment)

The CFTC Division of Market Oversight issued a letter providing swap dealers with time-limited no-action relief from swap data reporting obligations with respect to equity swaps, foreign exchange swaps and other commodity swaps. The letter provides swap dealers with reporting relief (i) under CFTC Rules Part 43 [Real-Time Public Reporting] and Part 45 [Swap Data Recordkeeping and Reporting Requirements] until February 28, 2013, and (ii) under CFTC Rule Part 46 [Swap Data Recordkeeping and Reporting Requirements: Pre-Enactment and Transition Swaps] until March 30, 2013. The footnotes to the letter provide more detailed useful guidance as to which requirements are how long delayed.

According to the CFTC, the delay was necessary in order to account for certain disruptions to the testing of swap data reporting systems caused by Hurricane Sandy.

Lofchie Comment: Additionally, global warming makes it necessary to delay implementation of the Lincoln Amendments. It's just too hot to move all those contracts. (We all know that there are numerous "deadlines" that are simply impossible to achieve.)

See: CFTC Letter 12-41: Part 43, Part 45 and Part 46 of the CFTC's regulations; No-Action