The Commodity Futures Trading Commission’s division of market oversight (DMO) has issued a time-limited no-action letter granting relief for bespoke or complex swaps from certain reporting obligations under Part 43 and Part 45 of the Commission’s regulations.
For bespoke or complex swaps as defined therein, the no-action letter provides that DMO will not recommend an enforcement action against (1) a reporting party for failure to report certain data fields required by Part 43 or (2) a reporting counterparty for failure to report certain data fields required by Part 45.
In addition, for certain bespoke or complex swaps that are uncleared inter-affiliate swaps, the letter provides no-action relief from certain confirmation data reporting obligations under Part 45.
The relief will expire on the earlier of such time that the relevant data elements can be electronically represented in the FpML schema or 30 June 2013.