CFTC Staff Letter 26-11: No-Action Letter Extending Compliance Deadline for Nodal Clear's Daily Reporting Under Regulation 39.19(c)(1)

Before the daily reporting fields were codified in appendix C, the instructions, reporting fields, and technical specifications for daily reporting were contained in the Reporting 1 17 C.F.R. § 39.19(c)(1). 2 Reporting and Information Requirements for Derivatives Clearing Organizations, 88 Fed. Reg. 53664 (Aug. 8, 2023). 3 Id. U.S. COMMODITY FUTURES TRADING COMMISSION Three Lafayette Centre 1155 21st Street, NW, Washington, DC 20581 Telephone: (202) 418-5000 www.cftc.gov

Mr. Ken McCracken
Guidebook, which the Division provides to DCOs to facilitate daily reporting. After Regulation 39.19(c)(1) was amended, the Division revised the Reporting Guidebook. 4

Ahead of the compliance deadline, the Division worked with DCOs to test the reporting fields and ensure that the revised Reporting Guidebook contains all the format and manner specifications necessary to facilitate compliance by DCOs with the daily reporting requirements. In January 2025, 5 and again in September 2025, 6 the Division extended the compliance deadline because certain DCOs required additional time to begin reporting in accordance with appendix C and the latest version of the Reporting Guidebook. The current compliance deadline is June 1,
2026. 7

Discussion of Request for No-Action Position
Nodal represents that, since the release of the revised Reporting Guidebook, it has worked diligently to address the new requirements. Despite this, as well as a rigorous development schedule with allocated resources, Nodal requires additional time to complete the appropriate testing and quality assurance processes of its reporting infrastructure. Nodal represents that it will be able to comply with the requirements of the revised Reporting Guidebook by October 31, 2026. No-Action Position Based on the facts presented and the representations Nodal has made, the Division will not recommend that the Commission take enforcement action against Nodal for failure to comply with the reporting requirements of Commission Regulation 39.19(c)(1) before October 31,
2026. 8
The position taken herein concerns enforcement action only and does not represent a legal conclusion with respect to the applicability of any provision of the Commodity Exchange Act or the Commission’s regulations. In addition, the Division’s position does not necessarily reflect the views of the Commission or any other division or office of the Commission. Because this position is based on the representations contained in Nodal’s request letter, any different, changed, or omitted material facts or circumstances may require a different conclusion or render this letter void. Finally, as with all no-action letters, the Division retains the authority to condition further, modify, suspend, terminate, or otherwise restrict the terms of this letter, at its discretion. 4 Commodity Futures Trading Commission Guidebook for Part 39 Daily Reports, Version 2.0.2, May 7, 2025. 5 CFTC Letter No. 25-01 (Jan. 6, 2025). 6 CFTC Letter No. 25-34 (Sept. 26, 2025). 7 Id. 8 While this position applies only to Nodal, the Division is willing to consider similar requests from other DCOs if necessary.

Mr. Ken McCracken
Sincerely,

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Richard Haynes
Acting Director
Division of Clearing and Risk