On January 15 2016 the Commodity Futures Trading Commission (CFTC) Division of Market Oversight extended no-action relief originally provided in CFTC Letter 13-41, which was issued on June 28 2013.

In relation to required reports in light of privacy, secrecy and blocking laws in certain jurisdictions, CFTC Letter 13-41 permits:

  • Part 45 and Part 46 reporting counterparties to mask legal entity identifiers and certain other enumerated identifiers and identifying terms; and
  • Part 20 reporting entities to mask identifying information.

The CFTC previously extended this relief through CFTC Letter 15-01 and is now further extending relief, subject to certain conditions, until the earlier of March 1 2017 or the date on which the reporting party no longer holds the requisite reasonable belief that privacy law bars reporting.

The press release is available at www.cftc.gov/PressRoom/PressReleases/pr7310-16.

For further information on this topic please contact Donna M Parisi, Geoffrey B Goldman or Azam H Aziz at Shearman & Sterling LLP by telephone (+1 212 848 4000) or email (dparisis@shearman.com, geoffrey.goldman@shearman.com or aaziz@shearman.com). The Shearman & Sterling website can be accessed at www.shearman.com.

This article was first published by the International Law Office, a premium online legal update service for major companies and law firms worldwide. Register for a free subscription.