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Apr 14, 2013

CFTC Swap Reporting No-Action Relief Granted; Other Dodd-Frank Deadlines Approaching

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On April 9, 2013, the US Commodity Futures Trading Commission (the “CFTC”) granted last minute no-action relief from portions of the CFTC’s swap reporting rules. The relief delays certain compliance deadlines for many swap market participants, including corporate end-users and buy-side financial institutions. The no-action relief generally grants financial entities (other than Swap Dealers and Major Swap Participants) and non-financial entities additional time to comply with their swap reporting obligations, but financial entities did not receive any additional time to report interest rate and credit swaps, and must have started reporting on April 10, 2013 if they are the reporting party. The CFTC has also granted separate no-action relief for the reporting obligations imposed on inter-affiliate swaps. There has been no extension of the deadline to comply with the CFTC’s swap recordkeeping requirements or the deadline for all swap market participants to obtain a legal entity identifier, for which the deadline remains April 10, 2013. Finally, Swap Dealers and Major Swap Participants must comply with external business conduct rules on May 1, 2013 and ISDA continues to encourage market participants to adhere to the August 2012 Dodd-Frank Protocol (“Protocol”) as quickly as possible in order to facilitate compliance with these rules.

View full memo, "CFTC Swap Reporting No-Action Relief Granted; Other Dodd-Frank Deadlines Approaching"

Authors and Contributors

Azam Aziz

Partner

Derivatives & Structured Products

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+1 212 848 8154

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Patrick Clancy

Partner

Finance

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+44 20 7655 5878

London

Thomas Donegan

Partner

Financial Institutions Advisory & Financial Regulatory

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+44 20 7655 5566

London

Geoffrey Goldman

Partner

Derivatives & Structured Products

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Donna Parisi

Partner

Derivatives & Structured Products

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+1 212 848 7367

New York

Barnabas Reynolds

Partner

Financial Institutions Advisory & Financial Regulatory

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Bradley K. Sabel

Of Counsel

Financial Institutions Advisory & Financial Regulatory

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James Duncan

Partner

Finance

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Nhung Pham

Counsel

Investment Funds

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