Washington, D.C. — The Commodity Futures Trading Commission’s Division of Data (DOD) today issued a no-action letter regarding the compliance dates for the November 25, 2020 amendments to the swap data reporting rules. The amendments became effective on January 25, 2021 with a May 25, 2022 compliance date, except for certain block and cap amendments to CFTC Regulations 43.4(h) and 43.6, which have a May 25, 2023 compliance date.

The letter states that DOD will not recommend that the Commission take an enforcement action against an entity for failure to comply with the amendments before December 5, 2022, and for failure to comply with the block and cap amendments before December 4, 2023, provided that the entity complies with the regulations that were in effect for Parts 43, 45, 46, and 49 on January 1, 2021.

The Commission previously discussed its intent in 2020 to require the use of the data transmission standard, ISO 20022, and the Unique Product Identifier when those standards became available. DOD clarified today that it currently expects those standards to be available for implementation no later than Q4 2023, at which time DOD expects the Commission will require the use of those standards.