News & Analysis as of

International Swaps and Derivatives Association No-Action Letters Commodities Futures Trading Commission

Eversheds Sutherland (US) LLP

CFTC eases swap data error correction notification requirements

On July 31, 2025, the Commodity Futures Trading Commission’s Division of Market Oversight (CFTC) issued a no-action letter granting relief to reporting counterparties from the swap data reporting error correction notification...more

Patomak Global Partners

CFTC Eases SDR Error Notification Requirements With New No-Action Relief

Reporting counterparties must correct any error in their SDR reporting “as soon as technologically practicable” and, “[i]n all cases, […] within seven business days” after its discovery. If they fail to do so, they must...more

Orrick, Herrington & Sutcliffe LLP

CFTC Issues Brexit-Related No-Action Relief Regarding Margin and Clearing Requirements

The CFTC recently published Brexit-related Letter No. 20-42 (December 4, 2020) in response to a request from the International Swaps and Derivatives Association, Inc. (ISDA). In its request, ISDA stated that the expiration of...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Derivatives in Review - July 2014

Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more

Wilson Sonsini Goodrich & Rosati

CFTC Extends Deadline to Comply with Certain Trading Documentation Requirements Under Dodd-Frank for Corporate End-Users of...

In late June 2013, the Commodity and Futures Trading Commission (CFTC) issued a no-action letter extending the period for certain corporate end-users of foreign exchange (FX) derivative transactions to comply with the trading...more

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