All swap market participants, including commercial end-users, should be aware of the April 10 deadline for CFTC swap reporting and recordkeeping requirements under Parts 43, 45 and 46, many of which will apply to U.S. swap counterparties that are not swap dealers or major swap participants. The CFTC is considering a range of requests for relief from the reporting requirements and the April 10 compliance date, though it is unclear when and what kind of relief will be forthcoming.
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Impending Swap Reporting Requirements to Impact All Swap Market Participants
Skadden, Arps, Slate, Meagher & Flom LLP