CFTC Letter 12-02: Sections 20.3 and 20.4; No-Action

View letter here.Date: 03/20/2012

The CFTC's Division of Market Oversight issued a letter to market participants providing temporary and conditional no-action relief for less than fully compliant reporting under the CFTC's large trader reporting system for physical commodity swaps and swaptions. Clearing organizations and clearing members began reporting under the system on November 21, 2011. This temporary relief is intended to provide sufficient time for the industry and the CFTC to transition to fully compliant reporting under new Part 20 of the CFTC's rules by July 2, 2012. The compliance date for potential swap dealers that are not clearing members is tied to the effective date of a final CFTC regulation further defining the term swap dealer. This no-action is only available to market participants making a good faith effort to comply with the new rules. In addition, parties relying on the no-action relief must submit month-end open interest reports to the Commission that cover the period from March 1, 2012, to June 30, 2012.

Cross References: CFTC Sections 20.3 and 20.4; 76 FR 43851.