Time-limited no-action relief for end users from the Form TO filing requirement under Commission regulation § 32.3(b)(2).

Extension of time-limited no-action relief with respect to certain Commodity Exchange Act provisions that may apply to Southwest Power Pool, Inc. and/or its participants.

CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief permitting Part 45 and Part 46 reporting counterparties to mask legal entity identifiers, other enumerated identifiers and other identifying terms, and permitting Part 20 reporting entities to mask identifying information in certain enumerated jurisdictions, in each case subject to conditions.

Extension of Time-Limited No-Action Relief with Respect to Certain Commodity Exchange Act Provisions That May Apply to Southwest Power Pool, Inc. and/or Its Participants

The Division will grant the above time-limited no-action relief from the requirements for SEFs to capture post-trade allocation information in their audit trail data and to conduct associated audit trail reviews of post trade allocations, and will not recommend that the Division take enforcement action against any SEF that does not capture post-trade allocations in its audit trail data or conduct associated audit trail reviews of post trade allocations, as required by Commission regulations 37.205(a) and (b)(2).

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.

As the Commission continues to consider the issues in the Proposed Amendment, the Divisions believe an extension of the no-action relief in CFTC Staff Letter No. 14-147 is warranted.

Wells Fargo requests no-action relief permitting the London Branch and its counterparties to comply with the relevant requirements applicable to its Foreign Clients in lieu of the Commissions Transaction-Level Requirements. Wells Fargo requests the no-action relief only with respect to swaps between the London Branch and its Foreign Clients. Based on the foregoing and the representations made by Wells Fargo, the Divisions believe that granting no-action relief is warranted.

On November 7, 2014, in response to a request from ISDA similar to that previously received,6 the Division issued CFTC Letter No. 14-136 extending the relief granted in CFTC Letter No. 14-26 until December 31, 2015. The Division explained that the rationale for relief was unchanged and it needed additional time to assess whether the relief should be permanent.

As noted in the Request Letter, the Commission has not yet issued comparability determinations as to whether the regulatory requirements of any foreign jurisdiction are comparable to and as comprehensive as the applicable requirements under the Commodity Exchange Act and Commission regulations with respect to the SDR Reporting Rules.5 While review of those requests for comparability determinations that have been received by the Commission continues, the Division believes that it would be appropriate to provide an extension of the time-limited no-action relief provided in CFTC Letter No.