On 30 May 2014, the US Commodity Futures Trading Commission’s (“CFTC”) Division of Swap Dealer and Intermediary Oversight announced the issuance of a time-limited no-action letter that provides relief to each of the five Canadian banks that are registered with the CFTC as swap dealers. The five Canadian banks covered by the no-action letter are: the Bank of Montreal, the Bank of Nova Scotia, the Canadian Imperial Bank of Commerce, the Royal Bank of Canada, and the Toronto Dominion Bank.
The letter provides no-action relief with respect to the requirement that swap dealers furnish risk exposure reports on a quarterly basis, as mandated by Regulation 23.600. In particular, the letter provides time-limited no-action relief covering the quarterly risk exposure reports for any fiscal quarter ending on or before 31 July 2014. Accordingly, the five Canadian banks covered by the letter will be required to provide their first quarterly risk reports to the CFTC for the fiscal quarter ending on 31 October 2014.
The full text of the CFTC no-action letter is available at: