CFTC Issues Advisory Regarding Swap Reporting Requirements

The CFTC Division of Market Oversight has issued an advisory to remind market participants of the swap reporting requirements that are now, or soon to be, in effect. End users must be in compliance with the reporting rules (swap data reporting, real time reporting of swaps, and reporting of historical swaps) beginning April 10, 2013. End users are not required to report their swaps with swap dealer or major swap participant counterparties. However, for a swap between two end user counterparties, the counterparties must agree, as a term of the swap, as to which counterparty shall be the “reporting counterparty.”

Swap dealers have been required to report interest rate and credit swaps since December 31, 2012 and equity, foreign exchange and other commodity swaps (including energy and agricultural swaps) since February 28, 2013. Swap dealers were required to report historical swaps in the same categories on January 30, 2013 and March 30, 2013, respectively. Major swap participants were required to begin reporting all such swaps on February 28, 2013.

Check frequently for updated information on the Dodd-Frank Act, the JOBS Act, and other important matters regarding regulation of derivatives and securities.

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.

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