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


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.


Written by:

Published In:

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Katten Muchin Rosenman LLP | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.