CFTC Issues No-Action Letter on Swap Data Reporting for Event Contracts

The Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk have issued a no-action letter concerning swap data reporting and recordkeeping regulations. This means that they will not recommend enforcement actions against designated contract markets, derivatives clearing organizations, or their participants for failing to comply with specific swap-related recordkeeping and reporting requirements related to fully collateralized event contract transactions.

This decision responds to multiple requests from market entities that list and clear event contracts, and it is expected to facilitate similar future requests, including modifications to previous no-action positions. The goal is to ensure consistent treatment of market participants and simplify the process for listing or clearing similar contracts.

Entities interested in listing or clearing such contracts can request a similar no-action position. If granted, they will be added to the appendix of the no-action letter, avoiding the need for repeated individual approvals and promoting uniform regulatory treatment.

This development is part of ongoing efforts by the CFTC to adapt its regulatory framework to evolving derivatives markets, particularly those involving innovative contract types like event contracts.