Jun 10, 2014 | Uncategorized

No-Action Relief for CTA Oral Recording Requirement

The CFTC’s Divisions of Market Oversight and Swap Dealer and Intermediary oversight have extended no-action relief for CTAs that are members of Designated Contract Markets or Swap Execution Facilities (SEFs) relating to Regulation 1.35(a), the oral recording requirement in connection with the execution of swaps.

Certain entities such as CPOs and unregistered members of a DCM or SEF are excluded from the requirement.  CTAs are not.  The entities were originally required to be compliant by December 21, 2013 but the CFTC has since provided temporary no-action relief.  The CFTC’s Divisions will not take enforcement action against a CTA that is a member of a SEF or a DCM prior to December 31, 2014.

Click here for the detailed version of the CFTC No-Action letter.