The Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk have issued a no-action position covering swap data reporting and recordkeeping requirements for fully collateralized event contract transactions executed on or subject to the rules of Railbird Exchange, LLC and cleared through Bitnomial Clearinghouse, LLC. The divisions will not recommend enforcement action against Railbird, Bitnomial, or their participants for failing to comply with certain swap-related recordkeeping requirements or for failing to report related data to swap data repositories. The supplemental letter also removes the condition in CFTC Letter No. 25-26 that had prohibited Railbird participants from clearing contracts through a third-party clearing member. The relief was issued in response to a request from Railbird and Bitnomial to modify Letter No. 25-26 so it would cover transactions cleared through Bitnomial and lift the restriction on third-party clearing, and it remains subject to the terms of the no-action letter.
Commodity Futures Trading Commission 2026-05-04
Commodity Futures Trading Commission grants no action relief on swap reporting and recordkeeping for fully collateralized event contracts on Railbird and Bitnomial
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 fully collateralized event contract transactions executed on or subject to the rules of Railbird Exchange, LLC and cleared through Bitnomial Clearinghouse, LLC. The divisions will not recommend enforcement action against Railbird, Bitnomial, or their participants for certain swap-related recordkeeping and reporting failures, and have removed a prior condition that prohibited participants from clearing contracts through a third-party clearing member, subject to the no-action letter.