CFTC Issues Temporary No-Action Relief to Non-Clearing Swap Dealers to Comply with Large Trader Reporting Requirements for Physical Commodity Swaps and Swaptions

The Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (DMO)  has announced the issuance of temporary no-action relief for reporting by non-clearing member swap dealers under the CFTC’s large trader reporting requirements for physical commodity swaps and swaptions.

This temporary relief is intended to provide sufficient time for non-clearing member swap dealers to transition to fully compliant reporting by 60 days after the Commission’s deadline for entities to apply to register as swap dealers. Any party relying on this relief must state that it is doing so in an e-mail to DMO: submissions@cftc.gov or SwapsLTR@cftc.gov, no later than the swap dealer registration application date.

In addition, DMO will provide an additional six months of no-action relief to non-clearing member swap dealers that satisfy the conditions of Section 20.10(e) of the Commission’s regulations. Parties relying on the limited extended relief must submit an e-mail to DMO (see email addresses above) that includes information regarding satisfaction of the Section 20.10(e) conditions, as well as arrangements being made to come into full compliance with the rules and the expected date of such compliance.

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