The Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk have issued a no-action letter stating they will not recommend enforcement action against designated contract markets, derivatives clearing organizations, or their participants for failing to comply with certain swap-related recordkeeping requirements and for failing to report to swap data repositories data associated with fully collateralized event contract transactions. The relief is subject to the terms of the no-action letter. The step responds to numerous requests from designated contract markets and derivatives clearing organizations that list and clear event contracts. It also extends to all beneficiaries of previous no-action letters covering data reporting for similar contracts. Entities that want to list or clear similar contracts may request an identical no-action position and, if granted, will be added to the appendix to the new letter. The divisions expect further requests, including changes tied to amended designated contract market designation orders, changes in derivatives clearing organizations, and other developments, with the new approach intended to avoid repeated issuance of identical letters and provide consistent treatment for existing and new applicants.

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