The CFTC Division of Market Oversight ("DMO") issued a no-action letter granting an extension of time-limited relief to swap dealers ("SDs") and Major Swap Participants ("MSPs"), previously granted in Letter 12-59 and expiring on June 30, 2013, from the obligation to report swap data under CFTC Rules Part 45 ("Swap Data Recordkeeping and Reporting Requirements") for cleared credit default swaps ("CDS"). The letter provides that the Division will not recommend the CFTC take enforcement action against an SD or MSP for their failure to comply with Part 45 reporting obligations for CDS Clearing

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

The CFTC's Division of Market Oversight ("DMO") issued a letter providing reporting parties under CFTC Rules Parts 20 ("Large Trader Reporting for Physical Commodity Swaps"), 45 ("Swap Data Recordkeeping and Reporting Requirements"), and 46("Swap Data Recordkeeping and Reporting Requirements: Pre-Enactment and Transition Swaps"), with time-limited no-action relief from requirements to report certain identifying information regarding their counterparties in specific jurisdictions. This no-action letter addresses Legal Entity Identifiers ("LEIs"), other identifying swap data fields pursuant to

The CFTC's Division of Swap Dealer and Intermediary Oversight ("DSIO") announced the issuance of a no-action letter relating to the portfolio reconciliation requirements imposed on swap dealers ("SDs") and major swap participants ("MSPs") pursuant to CFTC Rule 23.502. The relief, which was granted based on the fact that as a practical matter it was impossible to comply with the requirements of the rule, is available to all SDs and MSPs until August 23, 2013. Lofchie Comment:The process of setting deadlines that will likely require further extension is inefficient from the standpoint of both

The CFTC's Division of Swap Dealer and Intermediary Oversight ("DSIO") issued a no-action letter relating to requirements imposed on Swap Dealers ("SDs") and Major Swap Participants ("MSPs") pursuant to CFTC Rule 23.504 ("Swap trading relationship documentation") in connection with: (i) foreign exchange transactions that are swaps, and (ii) physically-settled foreign exchange forwards and swap agreements that have been exempted from the definition of "swap" by the Secretary of the U.S. Department of the Treasury. The letter provides relief for SDs and MSPs from the requirements of swap trading