On March 20, the Commodity Futures Trading Commission’s Division of Market Oversight issued a no-action letter providing temporary and conditional relief for clearing organizations and clearing members that fail to submit fully compliant reports under the CFTC’s large trader reporting system for swaps and swaptions. In order to qualify for relief, reporting parties must make a good-faith effort to comply with the large trader reporting requirements and clearing organizations and reporting entities must provide open interest data for positions during the entire relief period (March 1 through June 30) no later than the fifteenth day of the following month. The Division explained that good faith is demonstrated by filing otherwise fully compliant reports in an interim pipe-delimited text format.

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