On January 8, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) granted an extension of previously issued no-action relief for parties required to report identifying information relating to their swap counterparties.
CFTC Letters 13-41 and 14-89 granted time-limited no-action relief for certain CFTC reporting counterparties to mask legal entity identifiers and other enumerated identifiers and identifying terms in reports made to swap data repositories pursuant to Parts 45 and 46 of CFTC Regulations and to the CFTC pursuant to Part 20 of CFTC Regulations. A reporting party may rely on the extension of relief only to the extent that it previously satisfied the conditions set forth in CFTC Letter No. 13-41, which includes receiving a formal response from the applicable non-US regulator or governing authority.
The extension of relief expires on the date the reporting party no longer holds the requisite reasonable belief regarding the privacy law consequences of reporting or 12:01 a.m. (ET) on January 16, 2016, whichever occurs first.
CFTC Letter No. 15-01 is available here.
elief to Certain Reporting Counterparties Masking Identifying Information Pursuant to Non-US Law