On January 13, 2015, the CFTC issued No-action Letter 15-01, which further extends to January 16, 2016 relief originally granted in No-action Letter 13-41 (No-action 13-41) from certain Title VII Dodd-Frank swap data reporting obligations under Parts 20, 45 or 46 of the CFTC's regulations for certain data, the dissemination of which is prohibited by certain enumerated jurisdictions.

These enumerated jurisdictions are:

The relief covers Legal Entity Identifiers (LEIs) and other identifying swap data fields under Part 45 (final SDR rules), Part 46 (final historical swap data reporting rules) and Part 20 (large swap trader counterparty identification rules) (see Legal Update, CFTC Issues No-action Letters Giving Swap Dealers More Time to Comply with Dodd-Frank Rules: Data Reporting Confidentiality). The data that is covered includes any identifying information that would intrinsically reveal the identity of the counterparty or its affiliated group and which is subject to statutory or regulatory prohibitions of one of the enumerated jurisdictions.

This relief was originally extended in No-action Letter 14-89 and was set to expire on January 16, 2015 (see Legal Update, Dodd-Frank Swaps Roundup: CFTC Extends Position Limits Comment Period, Limited Data Reporting Relief and More: No-action Letter 14-89: Data Reporting Confidentiality Relief).

The CFTC also adjusted the definition of "Part 20 Identifying Information" found in No-action 13-41 by adding certain data elements to account for privacy law counterparty information required under new Form 102S (see Legal Updates, Final Large-trader Reporting Rule Issued by CFTC and Dodd-Frank Swaps Roundup: Ownership and Control Data Reporting, Swap Dealer Rule Correction and More).

The further extension of relief is intended to provide additional time for relevant jurisdictions and parties with reporting obligations to continue their efforts to resolve statutory or regulatory prohibitions to reporting data. The extended relief will expire on the earlier of: