SIFMA AMG Submits Comments to the CFTC Requesting No-Action Relief Extending Compliance Date 3 Reporting Obligations (with Lofchie Comment)

The Asset Management Group (AMG) of SIFMA submitted the attached comment letter to the CFTC requesting that the Commission grant an extension of the compliance date for the reporting obligations under CFTC Rules Parts 43 (real time public reporting) 45 (swap data record keeping and reporting) and 46 (swap data record keeping and reporting for pre-enactment and transition swaps) applicable to non-swap dealers and non-major swap participants until October 10, 2013.

SIFMA AMG stated that it agrees with other industry groups that many non-swap dealers and non-major swap participants have yet to develop the technological capability, processes and procedures for complying with the Reporting Rules. Additionally, SIFMA believe that there still remain difficulties in onboarding and testing reporting system functionality with swap data repositories that continues to delay full compliance by the April 10, 2013 deadline.

Lofchie Comment: As pre-enactment date swaps recede further and further into history, I become more and more puzzled why the CFTC continues to require information as to these swaps. This is particularly so as there seems no way that the CFTC will be able to make any meaningful use of the information that it receives. If ever there was a case for a cost-benefit analysis, here it is.

Click hereto view letter in full (links externally to SIFMA website).