CFTC staff grants event-contract reporting no-action relief
Event-contract venues need no-action letter coverage before skipping SDR reporting
Change
CFTC staff issued a no-action position for specified swap data reporting and recordkeeping requirements tied to fully collateralized event contract transactions, covering DCMs, DCOs and participants subject to the letter’s terms.
Why it matters
The no-action letter creates a conditional staff non-enforcement boundary for event-contract reporting and recordkeeping. Relief is not automatic for every event contract or every venue; it applies to covered beneficiaries and to entities added through the request-and-appendix process. Operators outside the letter’s terms remain exposed to the underlying swap data reporting and recordkeeping requirements.
Implications
- — Designated contract markets listing fully collateralized event contracts must confirm they are covered by the no-action letter or appendix before relying on staff non-enforcement — otherwise swap data reporting and recordkeeping obligations remain operative.
- — Derivatives clearing organizations clearing covered event contracts must align clearing workflows with the no-action letter’s terms — relief applies only to specified transactions and requirements.
- — Market participant compliance teams trading fully collateralized event contracts through covered DCMs or DCOs must check venue and clearing coverage before treating SDR reporting and recordkeeping as relieved.
- — Entities seeking to list or clear similar contracts must request identical no-action treatment and wait to be added to the appendix — prior letters do not automatically cover new requesters unless the CFTC staff grants the request.
Who is affected
- — Designated contract markets listing fully collateralized event contracts
- — Derivatives clearing organizations clearing event contracts
- — Market participant compliance teams trading covered event contracts
- — Legal teams requesting CFTC no-action treatment for similar contracts