On December 10th, the CFTC's Division of Market Oversight issued a letter providing reporting parties under Parts 20, 45 and 46 of the CFTC's regulations with time-limited no-action relief from requirements to report certain identifying information regarding their non-reporting counterparties. The no-action letter addresses Legal Entity Identifiers, other identifying swap data fields pursuant to Parts 45 and 46, and large swap trader counterparty identification information pursuant to Part 20. To avail themselves of the relief, reporting parties must meet specific criteria set forth in the no-action letter, and must also comply with certain conditions. The no-action letter permits reporting parties to fulfill their reporting obligations while acknowledging certain non-U.S. privacy laws, provided that specific conditions are met. The relief expires no later than June 30, 2013.
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