no-action relief

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On April 28, the Division of Data of the Commodity Futures Trading Commission issued a renewal of the temporary no-action relief available to entities (Relief Counterparties) that submit certain swaps for clearing by derivatives clearing organizations that operate pursuant to CFTC exemptive orders or staff no-action letters (Relief DCOs). CFTC Letter No. 21-12 extends relief…

On April 22, the Commodity Futures Trading Commission’s Division of Data, Division of Market Oversight and Division of Clearing and Risk (collectively, the Divisions) issued CFTC Letter No. 21-11, which (1) provides no-action relief to KalshiEX LLC (Kalshi), a designated contract market, and LedgerX, LLC (LedgerX), a derivatives clearing organization, from reporting to swap data repositories data for binary option transactions executed on or subject to the rules of Kalshi and cleared by LedgerX; and (2) exempts Kalshi and LedgerX from certain related recordkeeping requirements.
Continue Reading CFTC Issues Conditional Relief From Reporting Fully Collateralized Binary Option Data to Swap Data Repositories

On April 8, the Market Participants Division (MPD), Division of Clearing and Risk (DCR), Division of Data (DOD) and Division of Market Oversight (DMO) of the Commodity Futures Trading Commission jointly issued no-action relief, effective immediately, to maintain the regulatory status quo for swap dealers (SD) following the withdrawal of the United Kingdom from the…

On April 14, the Commodity Futures Trading Commission’s Market Participants Division (MPD) and Division of Market Oversight (DMO) jointly issued CFTC Staff Letter 21-10 to extend, for a limited time, parts of the temporary no-action relief granted in response to the COVID-19 pandemic, which expired on April 15.
Continue Reading CFTC Staff Issues Continuation of Certain No-Action Relief to Market Participants in Response to COVID-19

On January 19, the Commodity Futures Trading Commission’s Market Participants Division (MPD) and Division of Market Oversight (DMO) issued CFTC Staff Letter No. 21-04 and Letter No. 21-05 (the Staff Letters) to extend, for a limited time, parts of the temporary no-action relief granted in response to the COVID-19 pandemic, which expired on January 15.
Continue Reading CFTC Staff Provides Limited Continuation of Certain No-Action Relief to Market Participants in Response to COVID-19

On January 4, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division (MPD) issued Staff Letter 21-02 providing temporary no-action relief to permit futures commission merchants (FCM) to invest customer funds in investments that have adjustable rates of interest that correlate closely with, or are determined solely by reference to, a benchmark of the Secured Overnight Financing Rate (SOFR), recognizing the increasing use of SOFR as an alternative reference rate to LIBOR in financial markets.
Continue Reading CFTC Staff Provides Temporary Relief to Futures Commission Merchants Regarding Certain SOFR-Linked Investments

On November 24, the Commodity Futures Trading Commission’s (CFTC) Division of Data (DOD) granted temporary no-action relief to DTCC Data Repository LLC (DDR) from certain requirements of the swaps data repository (SDR) rules in Part 49 of the CFTC’s regulations. DDR requested relief because it planned to implement revisions to its infrastructure and applications consistent with recent amendments to the CFTC’s reporting rules prior to the effective date of such rules.
Continue Reading CFTC Staff Grants Temporary Relief to DTCC Data Repository LLC and Related Entities from Reporting Requirements

On November 30, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight extended previously provided no-action relief for swap execution facilities (SEF) from certain timing requirements to file fourth-quarter financial reports and annual compliance reports.
Continue Reading CFTC Extends Timing Requirements for Certain SEF Year-End Reports

On November 19, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) issued a staff letter extending no-action relief to certain CFTC-registered swap dealers (SDs) and major swap participants (MSPs). The no-action relief, which was initially granted in 2013 and subsequently extended several times, was set to expire on December 1.
Continue Reading CFTC Extends Temporary Swap Data Reporting Relief for Certain International Swap Dealers and Major Swap Participants

On November 13, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) issued CFTC Staff Letter No. 20-36, which extends no-action relief to swap execution facilities (SEFs) from the requirement to capture post-execution allocation information in their audit trail data.
Continue Reading CFTC Extends No-Action Relief to SEFs From Certain Audit Trail Requirements Related to Post-Execution Allocation Information