CFTC Issues Multiple No-Action Letters on Reporting and Business Conduct Rules

3 July 2013
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Key takeaways:

  • The CFTC issued a number of no-action letters extending previously granted relief and granting additional relief in connection with the following requirements: portfolio reconciliation, swap trading relationship documentation, certain external business conduct standards and ongoing swap data reporting and real-time reporting.
  • Several no-action letters provide delayed compliance dates for swap dealers and major swap participants with respect to portfolio reconciliation, swap trading relationship documentation with respect to FX transactions, certain external business conduct standards, and certain reporting requirements with respect to particular types of swaps.
  • While most of the relief is self-executing, any entity wishing to rely on the no-action relief from the obligation to report certain identifying information regarding their counterparties in certain specified jurisdictions must submit certain information to the CFTC by August 27, 2013.