RegAlert2012-12-14 | CFTC Staff Letter 12-51Added · Updated
CFTC Staff Letter 12-51: Clarification and Extension of No-Action Relief for Non-Clearing Member Swap Dealers from Large Swap Trader Reporting
The Division of Market Oversight extends no-action relief from Section 20.4 reporting requirements for non-clearing member swap dealers, prohibiting enforcement actions for failures to report between December 11, 2012, and March 1, 2013. Entities relying on this relief must notify the Division via email by their swap dealer registration application date. Section 20.10(e) swap dealers receive extended relief until September 1, 2013, provided they submit a specific email certification detailing resource limitations and compliance arrangements. On and after March 1, 2013, all entities must comply with Part 20 reporting requirements by the date they become a swap dealer, defined as the earlier of registration application or the swap dealer registration deadline.
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U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5260
Facsimile: (202) 418-5527
Division of
Market Oversight
CFTC Letter No. 12-51
No-Action
December 14, 2012
Division of Market Oversight
Paul J. Pantano, Jr.
Cadwalader, Wickersham & Taft LLP
700 Sixth Street, NW
Washington, DC 20001
Clarification of Division of Market Oversight No-Action Letter 12-04 (July 17, 2012), and Extension of No-Action Relief for Non-Clearing Member Swap Dealers from Large Swap Trader Reporting Requirements of Section 20.4 of the Commission’s Regulations Dear Mr. Pantano:
By letter dated December 6, 2012, to the Division of Market Oversight (“Division”) of the Commodity Futures Trading Commission (“Commission”), and pursuant to Section 140.99 of the Commission’s regulations, you request on behalf of your client, the Futures Industry Association (“FIA”), clarification of the timeline, as contemplated pursuant to a no-action letter issued by the Division on July 17, 2012 (the “No-Action Letter”), 1 within which swap dealers that are not clearing members (“non-clearing member swap dealers”) must come into compliance with the large swap trader reporting requirements of Part 20 of the Commission’s regulations. You request this clarification in light of Commission staff guidance issued subsequent to the issuance of the No-Action Letter, 2 regarding Section 1.3(ggg)(4) of the Commission’s regulations (the “de minimis exception”). 3 The Division is issuing this letter to clarify the compliance timeline contemplated by the NoAction Letter, and to extend the reporting relief provided to non-clearing member swap dealers in the No-Action Letter. The extended no-action relief is provided to non-clearing member swap dealers regardless of whether they are members of FIA.
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Source: Commodity Futures Trading Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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CFTC published 6 documents in the last 30 days. We email you each new one the day it's published.