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ARTICLE · 15 APRIL 2013

Swaps End-User Update - Relief From Certain Swap Reporting Requirements For Inter-Affiliate Swaps

McGuireWoods LLP
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A brief update for those who are end-users of swaps.

United StatesFinance and Banking
Karl Strait
Karl Strait
D. Cameron Prell
D. Cameron Prell
Walter White, Jr.
Walter White, Jr.
Mehboob Dossa
Mehboob Dossa

The following is a brief update for our clients and friends who are end-users of swaps (for example, interest rate, commodity, energy or currency/FX swaps).

Late Friday, April 5, 2013, the Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk issued no-action relief for swaps entered into between affiliates of certain wholly-owned and majority-owned market participants from the requirement to report their intra-group swaps to a registered swap data repository (SDR), under Part 45 (for post-compliance date swaps), Part 46 (for pre-enactment and transition swaps), and Regulation 50.50(b) (for the election of the end-user exception to swap clearing) of the CFTC’s regulations, subject to several conditions.

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