Requesting No-Action Relief Extending Compliance Date 3 Reporting Obligations

The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting that the CFTC grant an extension of the compliance date for the reporting obligations under Part 43, Part 45, and Part 46 of the CFTC’s regulations applicable to non-swap dealers and non-major swap participants for six months, from April 10, 2013 to October 10, 2013.  SIFMA AMG agrees with other industry groups that many non-swap dealers and non-major swap participants have yet to develop the technological capability, processes and procedures for complying with the Reporting Rules.  Additionally, there still remain difficulties in onboarding and testing reporting system functionality with swap data repositories that continues to delay full compliance by the April 10, 2013 deadline.