Key takeaways:

• The CFTC has granted temporary no-action relief to swap dealers and major swap participants from certain recordkeeping requirements of subpart F to part 23 of its regulations.
• The no-action relief is valid through March 31, 2013 and is based upon certain representations made by SIFMA member firms and other SDs and MSPs in a letter to the CFTC's Division of Swap Dealer and Intermediary Oversight.
• The no-action relief applies to the requirements to: (1) maintain telephonic recordings of communications related to pre-execution trade information for swaps and related cash and forwards transactions; (2) maintain transaction and daily trading records in a manner identifiable and searchable by transaction and counterparty; (3) use Coordinated Universal Time to timestamp a swap's trade information prior to and at the time of execution of a swap; and (4) retain swap records at their principal place of business or other principal offices.