Title: 15-67
ISDA indicates that the industry should be able to review all swaps within 10 minutes after execution by May 1, 2016. Other industry participants have indicated that they should be able to do so by August 1, 2016. Therefore, the AQATP standard may be met if trades are routed to and received by the relevant DCO no more than 10 minutes after the execution of the trade, effective on August 1, 2016 and thereafter. Staff notes that the reporting obligations of SEFs and DCMs contained in Regulations 43 and 45 are not affected by this letter. In particular, a SEF or DCM must report a swap transaction to the appropriate Swap Data Repository as soon as technologically practicable after execution of the swap in accordance with Regulations 43.3 and 45.3 regardless of when the swap is submitted for clearing.Market participants should be aware that the positions taken herein do not excuse affected persons from compliance with any other applicable requirements of the CEA or the Commission’s regulations thereunder, in particular, the applicable swap data reporting requirements, clearing requirements, pre-execution credit check requirements, and straight-through processing requirements.