CFTC No-Action Relief from Post-Allocation Swap Timing Requirements

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On December 13, the CFTC issued a letter providing relief from the post-allocation swap timing requirement of § 45.3(e)(ii)(A). The no-action letter permits parties to a swap to fulfill reporting obligations for post-allocation swaps in a timely manner while acknowledging jurisdictional, global time zone, and legal holiday differences. The relief expires no later than June 30, 2013. CFTC Release. No-Action Letter.