Key takeaways:

• 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.