CFTC – Staff Provides Temporary No Action Relief from Certain Financial Reporting Requirements to Bank Swap Dealers

August 31, 2021 – CFTC issued temporary no action relief from CFTC rule financial reporting requirements to bank swap dealers that are subject to capital requirements of a prudential regulator. No action letter in response to SIFMA/ISDA joint letter requesting no enforcement of reporting under CFTC CFR 23.105(p)(2), would have had to comply by October 6. 2021.

Alternative Reporting Request: Bank SDs may report on alternative forms, follow alternative filing deadlines and/or reporting standards subject to conditions detailed in letter if they comply with prudential standards. Specifically bank SDs that file Call Reports can submit Schedule RC instead of CFTC rule required balance sheet/statement of regulatory capital on Appendix C similar now. Allow submission within 35 days of calendar Q, instead of 30 days for App C. Covered non-US bank SDs that do not file call reports may use home country reports. If dually registered with SEC, may file FOCUS Report Part IIC instead of CFTC App. C.

Conditions and Effectiveness: CFTC allowed alternative reporting and specified all non-US bank reports must be filed in English, in compliance with local deadlines or Call Report submission requirements. To be immediately effective, relief in place until October 6, 2023 or the date of adoption of new rules.

For more information, visit www.cftc.gov.

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