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 (firstname.lastname@example.org, email@example.com or firstname.lastname@example.org). The Shearman & Sterling website can be accessed at www.shearman.com.
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