2013-03-30 | CFTC Staff Letter 13-06

Added · Updated

CFTC Staff Letter 13-06: No-Action Relief for Swap Dealers and Major Swap Participants from Certain Internal Business Conduct Requirements

The Division of Swap Dealer and Intermediary Oversight will not recommend enforcement actions against swap dealers and major swap participants for failing to comply with specific recordkeeping requirements under Regulations 23.201, 23.202, and 23.203 until June 30, 2013. This relief exempts firms from recording landline telephone conversations in jurisdictions outside the United States, United Kingdom, Singapore, Hong Kong, Japan, Australia, Switzerland, and Canada, and allows transaction records to remain searchable via existing system capabilities rather than requiring immediate identifiability by transaction and counterparty. Additionally, firms may continue using local time for legacy system timestamps provided the data is convertible to Coordinated Universal Time upon regulatory request, and may retain records outside the principal place of business if they are promptly available at a designated U.S. location within 72 hours of a Commission representative's request.

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