CFTC Issues Time-Limited No-Action Relief for Swap Dealers From Certain Swap Data Reporting Requirements of Part 43, Part 45 and Part 46 of the Commission's Regulations (Letter No. 12-32)

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On November 19, 2012, the Division of Swap Dealer and Intermediary Oversight ("DSIO") and the Division of Market Oversight ("DMO") of the Commodity Futures Trading Commission ("CFTC") issued CFTC Letter No. 12-32 ("Letter No. 12-32") (available here) on matters concerning reporting requirements for Swap Dealers ("SDs").

Letter No. 12-32 provides SDs who register prior to their deadline (as discussed below) time-limited no-action relief with respect to certain requirements of Parts 43 (real-time public reporting of swap transaction data), 45 (swap data recordkeeping and swap data repository ("SDRs") reporting requirements) and 46 (swap data recordkeeping and SDR reporting requirements for historical swaps*) of the CFTC regulations (collectively referred to herein as the "Reporting Rules").

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