CFTC Extends No-Action Relief To Non-U.S. SDs From Swap Data Reporting Requirements

The CFTC Division of Market Oversight ("DMO") extended previously issued no-action relief to non-U.S. swap dealers ("SDs") from certain swap data reporting requirements.

CFTC Letter 20-37 extends prior relief (covered here) to non-U.S. SDs that (i) are established in Australia, Canada, the European Union, Japan or Switzerland, and (ii) are not part of an affiliated group in which the ultimate parent entity is U.S.-based. For these entities, the relief addresses swaps which are entered into with non-U.S. counterparties that are not guaranteed affiliates or conduit affiliates.

The relief was originally granted by CFTC Letter 13-75 and most recently extended by CFTC Letter 17-64.