CFTC Staff Letters

No-Action Position to a SD Regarding the Public Disclosure of Certain Financial Information under SD Financial Reporting Requirements

DOD is taking a time-limited no-action position with respect to the compliance dates for the November 25, 2020 amendments to certain of the swap data reporting rules in Parts 43, 45, 46, and 49.

No-Action Relief permitting certain Foreign-Based SD to File Annual Financial Reports pursuant to Regulation 23.105(e) in Accordance with Singapore Financial Reporting Standards (Morgan Stanley - J. Aron Singapore Accounting No-Action Relief Request)

No-Action Position for Foreign-Based SD to File Annual Financial Reports in Accordance with Australian Accounting Standards Board (Goldman Sachs No-Action Relief Request)

DCR is extending through June 27, 2022 temporary no-action relief for registered derivatives clearing organizations (DCOs) from the amended daily reporting requirements in CFTC Regulation 39.19(c)(1), so long as DCOs continue to comply with the prior version of the regulation. DCR also is extending through January 27, 2023 relief from the amended reporting requirements in Regulation 39.19(c)(1)(i)(B) and (C), so long as DCOs continue to comply with the prior version of the regulation.

DOD is taking a no-action position with respect to certain Part 43 and Part 45 swap reporting obligations for swaps transitioning under the ISDA LIBOR fallback provisions from referencing certain London Interbank Offered Rates (LIBORs) to referencing risk-free rates (RFRs) following the cessation or non-representativeness of those LIBORs on December 31, 2021. (ARRC No-Action Relief Request)

DCR and MPD are further extending the time limit for conditional, time-limited no-action relief from 39.13(g)(8)(iii), first issued in Letter 19-17 and extended in Letter 20-28 until September 30, 2022. (FIA No-Action Request Extension)

DCR is providing time-limited relief from the swap clearing requirement and related exceptions and exemptions. This relief is to help facilitate the orderly transition from swaps that reference the London Interbank Offered Rate (LIBOR) and other interbank offered rates to swaps that reference alternative benchmarks. (ARRC No-Action Relief Extension Request)

DMO is providing time-limited relief from the trade execution requirement in order to facilitate the orderly transition from swaps that reference the London Interbank Offered Rate (LIBOR) and other interbank offered rates to swaps that reference alternative benchmarks.  (ARRC No-Action Relief Extension Request)

MPD is providing relief to swap dealers from registration de minimis requirements, uncleared swap margin rules, business conduct requirements, confirmation, documentation, and reconciliation requirements, and certain other eligibility requirements. This relief is to help facilitate the orderly transition from swaps that reference the London Interbank Offered Rate (LIBOR) and other interbank offered rates to swaps that reference alternative benchmarks. (ARRC No-Action Relief Extension Request)