# CFTC Letter No. 25-18: Extension of no-action position with respect to Part 45 for entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating consistent with CFTC exemptive orders or no-action positions pr..

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/CFTC_L25_18

## Section

- **Citation:** CFTC Letter No. 25-18
- **Heading:** Extension of no-action position with respect to Part 45 for entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating consistent with CFTC exemptive orders or no-action positions pr..
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** CFTC Staff Letters (2008-present) / Extension of no-action position with respect to Part 45 for entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating consistent with CFTC exemptive orders or no-action positions pr...

## Text

Summary: Extension of no-action position with respect to Part 45 for entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating consistent with CFTC exemptive orders or no-action positions provided by CFTC staff.

1

CFTC Letter No. 25-18 No-Action July 09, 2025

Rahul Varma

Acting Director

Re: Extension of No-Action Position Related to Certain Reporting Obligations for
Counterparties Clearing Swaps through Derivatives Clearing Organizations
Acting Under Exemptive Orders or No-Action Letters

Dear Mr. Young:

This letter responds to a request received by the Division of Market Oversight (“DMO”)
of the Commodity Futures Trading Commission (the “Commission” or “CFTC”) from the
International Swaps and Derivatives Association, Inc. (“ISDA”), pursuant to Commission
Regulation 140.99.1

ISDA has requested, on behalf of its members with swap data reporting obligations and
other similarly situated persons, that DMO renew the no-action position provided in CFTC Letter
No. 22-182 regarding certain reporting obligations under Part 45 of the Commission’s regulations
in connection with the clearing of swaps with derivatives clearing organizations (“DCOs”)
operating pursuant to (a) exemptive orders issued by the Commission,3 or (b) a no-action letter
granted by the Commission’s Division of Clearing and Risk (“DCR”).

1 Letter from Christopher Young, Head of U.S. Public Policy, ISDA, to Rahul Varma, Acting Director, Division of
Market Oversight, re: Request for Extension of CFTC No-Action Relief 22-18: No-Action Relief for SDR Reporting
Requiremnets for Swaps Cleared by Exempt and No-Action DCOs (June 30, 2025) (the “ISDA Letter”), to be available
at https://www.cftc.gov/LawRegulation/CFTCStaffLetters/letters.htm following issuance of this letter.
2 CFTC Letter No. 22-18 (Dec
Rahul Varma, Acting Director, Division of
Market Oversight, re: Request for Extension of CFTC No-Action Relief 22-18: No-Action Relief for SDR Reporting
Requiremnets for Swaps Cleared by Exempt and No-Action DCOs (June 30, 2025) (the “ISDA Letter”), to be available
at https://www.cftc.gov/LawRegulation/CFTCStaffLetters/letters.htm following issuance of this letter.
2 CFTC Letter No. 22-18 (Dec. 2, 2022), available at https://www.cftc.gov/csl/22-18/download, renewed a no-action
position taken in CFTC Letter No. 22-05 (May 25, 2022), available at https://www.cftc.gov/csl/22-05/download.
CFTC Letter 22-05 renewed a no action position extended in CFTC Letter No. 21-12 (Apr. 28, 2021), available at
https://www.cftc.gov/csl/21-12/download,
CFTC
Letter
No.
18-03
(Feb.
20,
2018),
available
at
https://www.cftc.gov/csl/18-03/download, and CFTC Letter No. 16-85 (Dec. 19, 2016), available at
http://www.cftc.gov/idc/groups/public/@lrlettergeneral/documents/letter/16-85.pdf.
3 The Commission adopted regulations for exempt DCOs in 2021. See Exemption From Derivatives Clearing
Organization Registration, 86 Fed. Reg. 949 (Jan. 7, 2021).
U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5000

Division of
Market Oversight

2

I.
Definitions for No-Action Position

Exclusively for the purposes of this letter, DMO will define the following terms:

(a) Relief DCO: Any DCO or central counterparty acting pursuant to a current and valid
exemptive order issued by the Commission (“Exempt DCO”), or a current and valid no-
action letter issued by DCR (“No-Action DCO”). As of the date of this letter, there are
five DCOs acting pursuant to exemptive orders: ASX Clear (Futures) Pty Limited, Japan
Securities Clearing Corporation, Korea Exchange, Inc., OTC Clearing Hong Kong
Limited, and Taiwan Futures Exchange Corporation.
valid
exemptive order issued by the Commission (“Exempt DCO”), or a current and valid no-
action letter issued by DCR (“No-Action DCO”). As of the date of this letter, there are
five DCOs acting pursuant to exemptive orders: ASX Clear (Futures) Pty Limited, Japan
Securities Clearing Corporation, Korea Exchange, Inc., OTC Clearing Hong Kong
Limited, and Taiwan Futures Exchange Corporation.

(b) Relief DCO Counterparty: Any market participant, not acting as a DCO or central
counterparty, that is a counterparty to a swap cleared by a Relief DCO.

(c) Relief DCO Original Swap: A swap reported or required to be reported pursuant to Part 45
of the Commission’s regulations that is subsequently accepted for clearing by a Relief
DCO.

(d) Relief DCO Clearing Swap: Any swaps created pursuant to the rules of a Relief DCO
between a Relief DCO and Relief DCO Counterparty.

(e) Relief Intended To Be Cleared Swap (“ITBC Swap”): Any swap which, at the time it is
executed, is intended by the counterparties to be cleared by a Relief DCO.

II.
Background

A. Certain Reporting Obligations

On June 27, 2016, the Commission published its final rule on Amendments to Swap Data
Recordkeeping and Reporting Requirements for Cleared Swaps (the “Cleared Swap Rule”).4 The
Cleared Swap Rule amended Part 45 of the Commission’s regulations5 to clarify or address certain
reporting obligations, including the obligations for DCOs to (a) report the termination of swaps
accepted for clearing by the DCO (defined as “original swaps” and known in the industry as “alpha
swaps”);6 (b) report creation data and continuation data for swaps to which the DCO is a
counterparty (defined as “clearing swaps”)7; and (c) generate the unique swap identifier (“USI”)
for each clearing swap and transmit that USI to the DCO’s counterparty.8

4 81 Fed. Reg. 41736 (June 27, 2016). The compliance date for the Cleared Swap Rule was December 27, 2016.
5 17 CFR part 45.
6 17 CFR § 45.4(c) (2016)
t creation data and continuation data for swaps to which the DCO is a
counterparty (defined as “clearing swaps”)7; and (c) generate the unique swap identifier (“USI”)
for each clearing swap and transmit that USI to the DCO’s counterparty.8

4 81 Fed. Reg. 41736 (June 27, 2016). The compliance date for the Cleared Swap Rule was December 27, 2016.
5 17 CFR part 45.
6 17 CFR § 45.4(c) (2016).
7 17 CFR § 45.3(e) (2016) (creation data for clearing swaps); 17 CFR 45.4(b) (2016) (continuation data for clearing
swaps).
8 17 CFR § 45.5(d) (2016). The Commision subsequently amended regulation 45.5 to require creation of unique
transaction identifiers (“UTIs”). See 17 C.F.R. § 45.5 (2025); see also Swap Data Recordkeeping and Reporting
Requirements, 85 Fed. Reg. 75503 (Nov. 25, 2020).

3

The Cleared Swap Rule defined “derivatives clearing organization” exclusively as a DCO
registered with the Commission.9 Because a Relief DCO would not be a “derivatives clearing
organization” for purposes of the Cleared Swap Rule, a swap accepted for clearing by a Relief
DCO would not be an “original swap” under § 45.4 of the Commission’s regulations.10 Therefore,
the obligation to terminate the Relief DCO Original Swap does not fall to the Relief DCO. Further,
Relief DCO Clearing Swaps are not considered “clearing swaps.” As a result, reporting
obligations for Relief DCO Clearing Swaps fell to the Relief DCO Counterparty (either a swap
dealer (“SD”), major swap participant (“MSP”), or non-SD/MSP counterparty) by operation of the
reporting hierarchy under § 45.8.11

Although not subject to reporting obligations imposed on registered DCOs under the
Cleared Swap Rule, Relief DCOs are required to fulfill many of the same obligations pursuant to
both § 39.6(d)12 and as a term of an exemptive order or as condition to no-action letters
r (“SD”), major swap participant (“MSP”), or non-SD/MSP counterparty) by operation of the
reporting hierarchy under § 45.8.11

Although not subject to reporting obligations imposed on registered DCOs under the
Cleared Swap Rule, Relief DCOs are required to fulfill many of the same obligations pursuant to
both § 39.6(d)12 and as a term of an exemptive order or as condition to no-action letters. As noted
above, there are currently five DCOs acting under exemptive orders issued by the Commission.13
Each of the exemptive orders includes the following requirement:

(10) Swap Data Recordkeeping and Reporting Requirements. If a clearing member clears
through [Relief DCO] a swap that has been reported to a Commission-registered swap data
repository (“SDR”) pursuant to Part 45 of the Commission's regulations, then [Relief DCO]
must report to an SDR, pursuant to this Order, data regarding the two swaps resulting from
the novation of the original swap that had been submitted to [Relief DCO] for clearing.
[Relief DCO] must also report the termination of the swap accepted for clearing by [Relief
DCO], to the SDR to which the swap was originally reported. In order to avoid duplicative
reporting for such transactions, [Relief DCO] shall have rules that prohibit the Part 45
reporting of the two new swaps by the original counterparties to the original swap.14

Although the exemptive orders have placed, and any Relief DCO no-action letter would
place, certain reporting obligations on the Relief DCOs, the exemptive orders do not, and a Relief
DCO no-action letter would not, provide any no-action position to the Relief DCO Counterparty
for any reporting obligations.

B. Certain Reporting Data Fields in Part 45

The Cleared Swap Rule’s definition of “derivatives clearing organization” implicates
certain data elements historically required to be reported for Relief ITBC Swaps
e Relief DCOs, the exemptive orders do not, and a Relief
DCO no-action letter would not, provide any no-action position to the Relief DCO Counterparty
for any reporting obligations.

B. Certain Reporting Data Fields in Part 45

The Cleared Swap Rule’s definition of “derivatives clearing organization” implicates
certain data elements historically required to be reported for Relief ITBC Swaps. Specifically, at

9 17 CFR § 45.1 (definition of “derivatives clearing organization”); Cleared Swap Rule, 81 FR at 41739 (declining to
extend the definition of “derivatives clearing organization” to include exempt DCOs). Although the Commission
recently amended certain Part 45 regulations, Swap Data Recordkeeping and Reporting Requirements, 85 Fed. Reg.
75503 (Nov. 25, 2020), the definition of “derivatives clearing organization” remains a DCO registered with the
Commission. Therefore, Relief DCO counterparties would still likely seek the no-action position described below
from their reporting obligations.
10 17 CFR § 45.4.
11 17 CFR § 45.8.
12 17 CFR § 39.6(d).
13 ASX Clear (Futures) Pty Limited, Japan Securities Clearing Corporation, Korea Exchange, Inc., OTC Clearing
Hong Kong Limited, and Taiwan Futures Exchange Corporation.
14 See, e.g., http://www.cftc.gov/idc/groups/public/@otherif/documents/ifdocs/asxclearamdorderdcoexemption.pdf
(ASX exemptive order). Any Relief NAL would include similar language.
4.
11 17 CFR § 45.8.
12 17 CFR § 39.6(d).
13 ASX Clear (Futures) Pty Limited, Japan Securities Clearing Corporation, Korea Exchange, Inc., OTC Clearing
Hong Kong Limited, and Taiwan Futures Exchange Corporation.
14 See, e.g., http://www.cftc.gov/idc/groups/public/@otherif/documents/ifdocs/asxclearamdorderdcoexemption.pdf
(ASX exemptive order). Any Relief NAL would include similar language.

4

the time the Cleared Swap Rule was promulgated in 2016, Part 45 required certain primary
economic terms data (“PET data”) be reported for each swap, including “Clearing indicator” data
and “Clearing venue” data, which referenced DCOs.15 Because Relief DCOs would not be
“derivatives clearing organizations” for purposes of those data fields, absent a no-action position,
the Cleared Swap Rule would require any entity reporting a Relief ITBC Swap to indicate that
such swap was not intended to be cleared.

On November 25, 2020, the Commission published amendments to Part 45.16 As part of
these amendments, the Commission replaced the old concept of PET data with new appendices
specifying the data elements to be reported.17 Staff has published updated technical specifications
that provide the form and manner for reporting those data elements to SDRs.18 Whereas Part 45
PET data incorporated the Cleared Swap Rule’s definition of “derivatives clearing organization”
for purposes of identifying swaps that were intended to be cleared, the newer technical
specifications instead use the term “central counterparty,” which is defined to include both a
“derivatives clearing organization” and an “exempt derivatives clearing organization.”19 The
current version of the technical specifications do not, however, explicitly state that the term
“central counterparty” also includes central counterparties acting pursuant to Relief DCO NALs.

III.
Requested No-Action Position With Respect To Certain Reporting Obligations
Under Part 45

ISDA requests the renewal of the no-action position in CFTC Letter No
es clearing organization.”19 The
current version of the technical specifications do not, however, explicitly state that the term
“central counterparty” also includes central counterparties acting pursuant to Relief DCO NALs.

III.
Requested No-Action Position With Respect To Certain Reporting Obligations
Under Part 45

ISDA requests the renewal of the no-action position in CFTC Letter No. 22-18 regarding
reporting obligations for counterparties facing Relief DCOs. Specifically, ISDA’s request covered
the following reporting obligations of counterparties that are neither DCOs nor central
counterparties:

1. Reporting swap continuation data for alpha swaps that have been accepted for clearing by
a Relief DCO;20
2. Reporting any creation data and continuation data for swaps resulting from novation of an
alpha swap accepted for clearing by a Relief DCO, as well as any related swaps which may
be entered into as part of post-trade activities including netting or compression exercises
or novations; and

15 See Swap Data Recordkeeping and Reporting Requirements, 77 Fed. Reg. 2136 (Jan. 13, 2012), App’x 1.
16 See Swap Data Recordkeeping and Reporting Requirements, 85 Fed. Reg. 75503 (Nov. 25, 2020). The compliance
date for regulations subject to those amendments was May 25, 2022. On January 31, 2022, the Division of Data issued
CFTC Letter No. 22-03, stating that the Division of Data would not recommend that the Commission take an
enforcement action against an entity for failure to comply with the regulations amending Part 45 before December 5,
2022. See CFTC Letter No. 22-03 (Jan. 31, 2022), available at https://www.cftc.gov/csl/22-03/download.
Accordingly, market participants implemented swap data reporting in the form and manner provided in the technical
specifications on December 5, 2022.
17 See id. at 75507.
18 See, e.g., Parts 43 and 45 swap data reporting and public dissemination requirements, Version 3.2 (Mar
re December 5,
2022. See CFTC Letter No. 22-03 (Jan. 31, 2022), available at https://www.cftc.gov/csl/22-03/download.
Accordingly, market participants implemented swap data reporting in the form and manner provided in the technical
specifications on December 5, 2022.
17 See id. at 75507.
18 See, e.g., Parts 43 and 45 swap data reporting and public dissemination requirements, Version 3.2 (Mar. 1, 2023),
available at https://www.cftc.gov/media/8261/Part43_45TechnicalSpecification03012023CLEAN/download.
19 See id. at 1 n.14.
20 ISDA requested a no-action position relating to ITBC Swaps with central counterparties exempted by the
Commission and central counterparties that received no-action letters from DCR. DMO has combined these two types
of central counterparties as “Relief DCOs” for purposes of this letter.

5

3. Generating Unique Transaction Identifiers (“UTIs”) for swaps created through the process
of clearing a swap with a Relief DCO.

ISDA requested that the no-action position remain in effect until the earlier of (a) the
revocation or expiration of the exemptive order or no-action letter issued to the relevant Relief
DCO, or (b) until further Commission action renders the no-action position inapplicable.

IV.
No-Action Position

Based on the facts presented and the representations that ISDA has made, DMO will not
recommend enforcement action to the Commission against Relief DCO Counterparties, solely for
failure to comply with the following reporting obligations:

a. Reporting continuation data pursuant to regulation § 45.4 on Relief DCO Original
Swaps after the acceptance of such Relief DCO Original Swaps for clearing by the
Relief DCO, including reporting the termination of the Relief DCO Original Swap;
b. Reporting creation data pursuant to regulation § 45.3 and continuation data pursuant to
regulation 45.4 on Relief DCO Clearing Swaps; and
c. Generating UTIs for Relief DCO Clearing Swaps pursuant to regulation § 45.5
DCO Original
Swaps after the acceptance of such Relief DCO Original Swaps for clearing by the
Relief DCO, including reporting the termination of the Relief DCO Original Swap;
b. Reporting creation data pursuant to regulation § 45.3 and continuation data pursuant to
regulation 45.4 on Relief DCO Clearing Swaps; and
c. Generating UTIs for Relief DCO Clearing Swaps pursuant to regulation § 45.5.

This no-action position is subject to the condition that the Relief DCO Counterparty must
provide to the Relief DCO all information on the Relief DCO Original Swap required by the Relief
DCO in its clearing agreement.

For Relief DCO Original Swaps and Relief DCO Clearing Swaps, the no-action position
taken herein will continue until the earlier of: (a) the revocation or expiration of the exemptive
order or no-action letter issued to the relevant Relief DCO; or (b) Commission action that renders
the no-action position inapplicable. Relief DCO Counterparties retain all other reporting
obligations for which they are responsible under the Commission’s regulations, and the no action
position herein does not apply if the Relief DCO rejects the swap for clearing.

In the ISDA Letter, ISDA requests clarification that reporting counterparties should report
a value of “Yes” in the cleared field for swaps intended to be submitted for clearing to a No-Action
DCO and report the LEI of the No-Action DCO in the central counterparty field for swaps intended
to be cleared at a No-Action DCO. Staff notes that under the no-action position taken here, Relief
DCO Original Swaps and Relief DCO Clearing Swaps are treated as original swaps and cleared
swaps for purposes of the Part 45 reporting requirements. Accordingly, it would be consistent
with the no-action position herein to treat the swaps cleared by a Relief DCO as cleared by a central
counterparty for purposes of the technical specifications
at under the no-action position taken here, Relief
DCO Original Swaps and Relief DCO Clearing Swaps are treated as original swaps and cleared
swaps for purposes of the Part 45 reporting requirements. Accordingly, it would be consistent
with the no-action position herein to treat the swaps cleared by a Relief DCO as cleared by a central
counterparty for purposes of the technical specifications.

*
*
*

This letter, and the no-action position taken herein, represent the views of the Division
only, and do not necessarily represent the position or views of the Commission or of any other
division or office of the Commission’s staff. This letter and the no-action position taken herein

6

are not binding on the Commission or other Commission staff.21 The no-action position taken
herein does not excuse affected persons from compliance with any other applicable requirements
contained in the Commodity Exchange Act or the regulations thereunder (in particular, the
applicable swap reporting requirements and clearing requirements). 22 Further, this letter, and the
position taken herein, are based upon the facts and circumstances presented to Division staff. Any
different, changed, or omitted material facts or circumstances might render this letter void. Finally,
as with all no-action letters, the Division retains the authority to condition further, modify,
suspend, terminate or otherwise restrict the terms of the no-action position provided herein, in its
discretion.

If you have any questions concerning this correspondence, please contact Isabella
Bergstein, Division of Market Oversight, at (202) 993-1384 or ibergstein@cftc.gov, Paul Chaffin,
Division of Market Oversight, at (202) 418-5185 or pchaffin@cftc.gov, or Owen Kopon, Division
of Market Oversight, at (202) 418-5360 or okopon@cftc.gov
of the no-action position provided herein, in its
discretion.

If you have any questions concerning this correspondence, please contact Isabella
Bergstein, Division of Market Oversight, at (202) 993-1384 or ibergstein@cftc.gov, Paul Chaffin,
Division of Market Oversight, at (202) 418-5185 or pchaffin@cftc.gov, or Owen Kopon, Division
of Market Oversight, at (202) 418-5360 or okopon@cftc.gov.

Sincerely,

_________________________
Rahul Varma
Acting Director
Division of Market Oversight

21 See 17 CFR § 140.99(a)(2) (“A no-action letter binds only the issuing Division . . . and not the Commission or other
Commission staff.”).
22 The applicable swap reporting requirements are set forth under Parts 43, 45, 46, and 50 of the Commission’s
regulations, 17 CFR parts 43, 45, 46 and 50, respectively. The applicable clearing requirements are set forth under
Commodity Exchange Act section 2(h)(1), 7 U.S.C. § 2(h)(1), and Part 50 of the Commission’s regulations.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CFTC_L25_18. Check the current official text before relying on it. Not legal advice.