No-Action Relief for Swap Dealers from Certain Swap Data Reporting Requirements Due to Hurricane Sandy

U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5000
Facsimile: (202) 418-5521 www.cftc.gov
Division of Market Oversight
CFTC Letter No. 12-41
No-Action
December 5, 2012
Division of Market Oversight
Robert Pickel
Chief Executive Officer
International Swaps and Derivatives Association, Inc.
360 Madison Avenue, 16 th Floor
New York, NY 10017
James Kemp
Managing Director
Global Foreign Exchange Division
Global Financial Markets Association
St. Michael’s House
1 George Yard
London, United Kingdom EC3V 9DH
No-Action Relief for Swap Dealers from Certain Swap Data Reporting Requirements of
Part 43, Part 45 and Part 46 of the Commission’s Regulations
Due to Effects of Hurricane Sandy
Mr. Pickel and Mr. Kemp:
By letter dated November 16, 2012 to the Division of Market Oversight (“Division”) of the Commodity Futures Trading Commission (“Commission”), and pursuant to Section 140.99 of the Commission’s regulations, you have requested, on behalf of those members of the International Swaps and Derivatives Association, Inc. and those members of the Global Foreign Exchange Division of the Global Financial Markets Association that will be subject to the Commission’s rules regarding the reporting of swap transaction data, and other similarly situated persons, temporary no-action relief to extend the date by which swap dealers must be in compliance with their swap data reporting obligations with respect to equity swaps, foreign exchange swaps and other commodity swaps (collectively, “Compliance Date 2 Swaps”), in order to account for certain disruptions to the testing and development of reporting systems caused by Hurricane Sandy. The Division has determined to extend such temporary relief to all swap dealers. By this letter, the Division provides swap dealers with no-action relief from swap data reporting obligations with respect to Compliance Date 2 Swaps: (i) under Part 43 and Part 45 of the Commission’s