CFTC Staff Letter 14-134: Time-limited no-action relief for Southwest Airlines long-dated crude oil swap reporting

U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5260
Facsimile: (202) 418-5527 www.cftc.gov
Division of
Market Oversight
CFTC Letter No. 14-134
No-Action
November 6, 2014
Division of Market Oversight
Time-Limited No-Action Relief: Further Time Delay for Public Dissemination of Long￾dated Brent and WTI Crude Oil Swap and Swaption Contracts Executed by or with Southwest Airlines. This letter is issued by the Division of Market Oversight (the “Division”) of the Commodity Futures Trading Commission (the “Commission”) to provide further time delay for real-time public reporting of long-dated Brent and WTI swap and swaption contracts not subject to the mandatory clearing requirement executed by or with Southwest Airlines (“Southwest”). Applicable Regulatory Requirements The Dodd-Frank Wall Street Reform and Consumer Protection Act 1 (the “Dodd-Frank Act”) added to the Commodity Exchange Act (the “CEA”) provisions requiring the retention and reporting of data related to swap transactions. Under new CEA section 2(a)(13)(C), the Commission “is authorized and required to provide by rule for the public availability of swap transaction and pricing data.” In exercising its statutory mandate, the Commission is authorized under section 2(a)(13)(C)(iii) to prescribe real-time public reporting of swaps not subject to the mandatory clearing requirement “in a manner that does not disclose the business transactions and market positions of any person.” The Commission published final rules under part 43 2 of the Commission’s regulations on January 9, 2012. 3 The rules implement a framework for the real-time public dissemination of swap transactions and pricing data for all swaps. Section 43.3(a) 4 provides that a reporting party