The Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk issued a no-action letter stating they will not recommend enforcement action against Gemini Titan, LLC, a designated contract market, and Gemini Olympus, LLC, a derivatives clearing organization, or their participants, for certain swap-related recordkeeping failures and failures to report swap data. The relief covers data associated with contracts with a binary payout structure and contracts with a variable payout structure that are executed on or subject to Titan’s rules and cleared through Olympus. The position is subject to the terms of the no-action letter and was issued in response to a request from Titan and Olympus to supplement CFTC Letter No. 25-44 so that it also covers transactions cleared through Olympus.
Commodity Futures Trading Commission 2026-05-01
Commodity Futures Trading Commission grants no-action relief to Gemini Titan and Gemini Olympus on certain swap reporting and recordkeeping obligations
The Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk issued a no-action letter providing relief to Gemini Titan, LLC and Gemini Olympus, LLC, and their participants, for certain swap-related recordkeeping and swap data reporting failures. The relief applies to data for binary and variable payout contracts executed on or subject to Titan’s rules and cleared through Olympus, and supplements CFTC Letter No. 25-44 by extending coverage to transactions cleared through Olympus.