CFTC Issues Time-Limited No-Action Relief for Reporting of Prime-Brokerage Swaps under CFTC Rules Parts 43 and 45

The CFTC Division of Market Oversight ("DMO") issued the attached time-limited no-action letter providing swap dealers with relief from Parts 43 and 45reporting for prime brokerage transactions. Subject to a variety of conditions, the initial burden of trade reporting will fall on the executing dealer that enters into a swap with a counterparty and not on the prime broker that enters into a back-to-back arrangement.

Compliance with the requirements of the letter will require prime brokers and executing brokers to enter into an agreement as to, among other things, the allocation between them of the responsibility for reporting the swap as per CFTC Rules. Expiration Date: June 30, 2013.

See: CFTC Letter 12-53: Parts 43 and 45; No-Action.