RegAlert2012-12-06 | CFTC Staff Letter 12-78Added · Updated
CFTC Staff Letter 12-78: No-Action Relief for Deutsche Bank Reporting Delays
The Division of Market Oversight grants time-limited no-action relief to Deutsche Bank regarding specific swap reporting obligations under Parts 43, 45, and 46 due to technological delays. The relief extends the deadline for reporting expired or terminated historical swaps under Part 46 until March 30, 2013, and allows execution timestamps for interest rate and other commodity swaps to be reported within 30 minutes of actual execution until June 30, 2013. Additionally, Deutsche Bank is permitted to delay linking initial Unique Swap Identifiers (USI) for novated or compressed swaps until June 30, 2013, and to withhold valuation data for multi-legged and exotic swaps until June 30, 2013. The letter also delays reporting document images for non-electronically confirmed FX and other commodity swaps until March 31, 2013, and FX transactions from Frankfurt and Johannesburg branches until June 30, 2013, subject to conditions requiring completion of SDR records by July 31, 2013.
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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. 12-78
No-Action
December 6, 2012
Division of Market Oversight
Chip Goodrich
Managing Director & Senior Counsel
Deutsche Bank
60 Wall Street
New York, NY 10005
Dear Mr. Goodrich:
This letter is in response to Deutsche Bank’s request dated November 30, 2012 (“Letter”), to the Division of Market Oversight (“DMO” or “Division”) of the Commodity Futures Trading Commission (“CFTC” or “Commission”). In the Letter, Deutsche Bank requested time-limited no-action relief with respect to certain reporting requirements promulgated by the Commission pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) under Parts 43, 1 45, 2 and 46 3 of the Commission’s regulations. Specifically, Deutsche Bank identified six areas in which full compliance with these reporting requirements, as they pertain to swap dealers, would not be possible as of the relevant compliance deadlines 4 due to unexpected delay in resolving various technological issues with
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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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