Key takeaways 

• The CFTC granted temporary no-action relief to reporting parties and reporting counterparties from certain swap data reporting requirements of Parts 43 and 45 of the Regulations with respect to bespoke or complex swaps which are not yet represented in Financial products Markup Language. 
• The no-action letter also grants relief from certain additional reporting requirements for bespoke or complex swaps that are uncleared inter-affiliate swaps for which paper confirmations are not generated. 
• The no-action relief will expire on the earlier of June 30, 2013 or such time as the relevant data elements can be electronically represented in FpML.