November 24, 2014

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November 21, 2014

CFTC Grants Temporary No-Action Relief from Swap Data Reporting Rules

The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission issued temporary no-action relief to swap dealers (SDs) from certain requirements of Parts 43, 45 and 46 of CFTC regulations (Swap Data Reporting Rules). This no-action relief was adopted in response to concerns raised by market participants that if no relief were granted, very few SDs would be initially registered, potentially allowing the market to identify the counterparties to the reported trades. Allowing the identity of counterparties to be discovered is a violation of CFTC Regulation 43.4(d)(1). The CFTC believes that this temporary no-action relief will help eliminate such concerns.

The CFTC no-action letter is available here.

©2014 Katten Muchin Rosenman LLP

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About this Author

Kevin M. Foley, Finance Attorney, Katten Muchin law Firm
Partner

Kevin M. Foley has extensive experience in commodities law and advises a wide range of clients, both in the United States and abroad, on compliance with the Commodity Exchange Act and the rules of the Commodity Futures Trading Commission (CFTC) affecting traditional exchange-traded products, as well as the over-the-counter markets involving swaps and other derivative instruments. His clients include futures commission merchants, derivatives clearing organizations, designated contract markets, foreign boards of trade and an industry trade association.

312-902-5372
Adam J. Spector, Katten Muchin Law firm, Financial Institutions Attorney
Associate

Adam J. Spector concentrates his practice in the financial services sector, representing hedge funds, commodity pools, proprietary trading firms, private equity funds and investment advisers with respect to their corporate, transactional and regulatory matters.

312-902-5275