The FAQs document also reminds trade option participants of certain reporting requirements under Parts 32 and 45 of the CFTC’s Regulations. For trade options in which neither counterparty is a swap dealer (SD) or major swap participant (MSP), the counterparties may report such trade options through an annual Form TO filing in lieu of reporting such trade options to a swap data repository pursuant to Part 45 of the CFTC’s Regulations. If a non-SD/MSP is already reporting other swaps to a swap data repository, then such non-SD/MSP must notify DMO via email no later than 30 days after entering into trade options having an aggregate notional value in excess of $1 billion in any calendar year to qualify for such relief.
DMO’s FAQs document is available here.
