U.S. Swap Dealers and Non-U.S. Major Swap Participants Under SDR Reporting Rules

Orrick - Finance 20/20

On November 9, the U.S. Commodity Futures Trading Commission’s (the “CFTC“) Division of Market Oversight issued a time-limited no-action letter extending the relief provided in CFTC Letter No. 14-141. The relief applies to non-U.S. swap dealers (“SD“) and non-U.S. major swap participants (“MSP“) established in Australia, Canada, the European Union, Japan or Switzerland that are part of an affiliated group in which the ultimate parent entity is a U.S. SD, U.S. MSP, U.S. bank, U.S. financial holding company, or U.S. bank holding company. The extension grants no-action relief to these entities for failing to comply with the swap data reporting requirements of Part 45 and Part 46 of the CFTC’s SDR Reporting Rules with respect to their swaps with non-U.S. counterparties that are not guaranteed affiliates, or conduit affiliates, of a U.S. person. Such relief will expire on the earlier of (i) 30 days after the CFTC issues a comparability determination with respect to the SDR Reporting Rules for the jurisdiction in which the non-U.S. SD or non-U.S. MSP is established or (ii) December 1, 2016. Press Release. No-Action Letter. No-Action Letter.

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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