CFTC Grants Temporary No-Action Relief from Certain Recordkeeping Requirements for Swap Dealers and Major Swap Participants

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The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued temporary no-action relief to swap dealers (SDs) and major swap participants (MSPs) from certain recordkeeping requirements set out in the internal business conduct requirements found in CFTC Rules 23.201, 23.202 and 23.203.

The letter provides that SDs and MSPs need not comply with the following recordkeeping requirements until April 1, 2013: (1) the requirement to record all oral communications relating to pre-execution swap trade information, including communications that ultimately lead to a related cash or forward transaction; (2) the requirement to maintain such record in a manner that is searchable by transaction and counterparty; (3) the requirement to timestamp pre-execution and execution trade information using Coordinated Universal Time; and (4) the requirement to maintain swap records at the SD’s or MSP’s principal place of business or other designated principal office.

The DSIO no-action letter is available here.

 

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Katten Muchin Rosenman LLP on:

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