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More Relief for Swap Dealers From Certain Swap Reporting Requirements and Political Contribution Prohibition
29 November 2012
The CFTC granted temporary no-action relief to swap dealers ("SDs") from certain swap data reporting requirements of Parts 43, 45 and 46 of its regulations, establishing a common monthly date by which all registered SDs must be in compliance with their ongoing reporting obligations and extending the deadline for reporting historical swap data.
The CFTC also granted no-action relief from its "pay-to-play" rulemaking under Regulation 23.451 of its external business conduct rules in connection with SDs' and their covered associates' dealings with certain "governmental plans," as defined in ERISA.
The CFTC clarified that, in determining whether a contribution by an SD or its covered associate to an official of a governmental Special Entity triggers the two-year prohibition on swaps trading with that entity, an SD need not "look back" beyond the date on which it is required to register as an SD.
Emilie T. Hsu
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