2012-12-21 | CFTC Staff Letter 12-66

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CFTC Staff Letter 12-66 (No-Action): Relief regarding the reporting of swap transaction data

The Division of Market Oversight grants swap dealers temporary no-action relief from enforcement for failing to comply with specific swap transaction data reporting requirements under Parts 43, 45, and 46 of the Commission’s regulations. This relief applies to swaps executed by branches in emerging market jurisdictions, exotic or multi-leg swap transactions, and subsequent trades linked to initial swaps via Unique Swap Identifiers, as well as certain life cycle events. The relief extends until April 30, 2013, or until the swap dealer resolves the technological issues preventing timely compliance, whichever occurs first. Swap dealers must document internal determinations of technical difficulty, retain records, and update systems to report in full compliance as soon as technologically practicable.

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