?Time-limited, no-action relief from compliance with valuation reporting obligations extended
No-action relief provided extended

Rulemaking comment period extended
Time-limited, no-action relief to futures commission merchants extended


Time-limited, no-action relief from compliance with valuation reporting obligations extended

On July 1 2014 the US Commodity Futures Trading Commission (CFTC) Division of Market Oversight extended the relief provided in No-action Letter 13-34. The letter provides relief to swap dealers and major swap participants from the obligation to report valuation data for cleared swaps as required by CFTC regulations. The letter provides that the CFTC will not take enforcement action against a swap dealer or major swap participant which fails to comply with such reporting requirements until June 30 2014.

No-action relief provided extended

On June 27 2014 the CFTC Division of Market Oversight issued a letter providing a time-limited extension of the relief provided in CFTC Letter 13-41. The letter, issued on June 28 2013, provides time-limited no-action relief for certain CFTC reporting counterparties to mask legal entity identifiers, other enumerated identifiers and other identifying terms, and permits certain reporting entities to mask identifying information in certain enumerated jurisdictions.

Rulemaking comment period extended

On June 27 2014 the CFTC announced a 30-day extension of the comment period for two rulemakings:

  • a proposal which would establish speculative position limits for 28 exempt and agricultural commodity futures and options contracts and the physical commodity swaps that are economically equivalent to such contracts; and
  • a proposal to amend existing regulations setting out the CFTC's policy for aggregation under its position limits regime.

Time-limited, no-action relief to futures commission merchants extended

On June 26 2014 the CFTC Division of Swap Dealer and Intermediary Oversight issued an extension of two previously issued time-limited, no-action relief actions (CFTC Letters 14-02 and 14-45) to the Futures Industry Association, its member futures commission merchants (FCMs) and similarly situated FCMs. The no-action letter extends relief from compliance with certain conditions associated with the receipt of customer funds by an FCM to October 31 2014.

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), fax (+1 212 848 7179) or email (dparisi@shearman.com, geoffrey.goldman@shearman.com or aaziz@shearman.com).The Shearman & Sterling website can be accessed at www.shearman.com.