On December 13th, the CFTC's Division of Market Oversight provided relief from the post-allocation swap timing requirement of Section 45.3(e)(ii)(A). The no-action letter provides extended post-allocation reporting deadlines for swaps that meet certain criteria and conditions. The no-action letter permits parties to a swap to fulfill their reporting obligations regarding post-allocation swaps in a timely manner while acknowledging jurisdictional, global time zone and legal holiday differences. The relief expires no later than June 30, 2013. CFTC Press Release.
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