The Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk issued a no-action position on swap data reporting and recordkeeping requirements for event contracts, responding to a request from Railbird Exchange, LLC and QC Clearing LLC. Under the no-action letter, the divisions will not recommend enforcement action against Railbird, QC Clearing, or their participants for failing to comply with certain swap-related recordkeeping requirements or for failing to report to swap data repositories data associated with binary option transactions and variable payout contract transactions executed on or subject to Railbird’s rules and cleared through QC Clearing, provided the letter’s terms are met. The relief is described as narrowly scoped and comparable to no-action letters previously issued for other similarly situated designated contract markets and derivatives clearing organizations.