CFTC No-Action Relief from Post-Allocation Swap Timing Requirements

On December 13, the CFTC issued a letter providing relief from the post-allocation swap timing requirement of § 45.3(e)(ii)(A).  The no-action letter permits parties to a swap to fulfill reporting obligations for post-allocation swaps in a timely manner while acknowledging jurisdictional, global time zone, and legal holiday differences.  The relief expires no later than June 30, 2013.  CFTC Release.  No-Action Letter.