On April 9th, the CFTC's Division of Market Oversight issued a no-action letter providing swap counterparties that are not swap dealers ("SDs") or major swap participants ("MSPs") with certain relief from the reporting requirements of the CFTC's swap data reporting rules. The CFTC's swap data reporting rules established an April 10, 2013 compliance date for counterparties who are not SDs or MSPs. The no-action letter provides two forms of relief. End-user counterparties who are not SDs or MSPs have been granted reporting relief under Parts 43 and 45: (1) for interest rate and credit swaps, until July 1, 2013, and (2) for equity, foreign exchange and other commodity swaps, until August 19, 2013. In addition, the no-action letter provides end-user counterparties with reporting relief under Part 46, for all swap asset classes, until October 31, 2013. "Financial entities" who are not SDs or MSPs, should have met the April 10, 2013 Part 43 and 45 compliance deadline for interest rate and credit swaps. However, the no-action letter provides these counterparties with reporting relief under Parts 43 and 45, with respect to equity, foreign exchange and other commodity swaps, until May 29, 2013. In addition, the no-action letter provides financial swap counterparties with reporting relief under Part 46, for all swap asset classes, until September 30, 2013. As a condition of relying on any relief from Part 43 and 45 reporting obligations that is provided in DMO's no-action letter, a non-SD/MSP counterparty must, within one month after the end of the applicable relief period, backload and report to a swap data repository all swap transaction data that the non-SD/MSP counterparty would have been required to report in the absence of the no-action relief. CFTC Press Release. CFTC Commissioner Scott O'Malia issued a highly-critical statement in connection with the agency's recent no-action announcements. O'Malia decried the ad hoc nature of the relief and the CFTC's failure to address the technological issues that not only face end-users, but the CFTC itself. O'Malia Statement.