Key takeaways 

• The CFTC granted temporary no-action relief from the timing requirements of Regulation 45.3(e) for swaps involving post-execution allocations where the agent and the reporting counterparty are located in different jurisdictions and different time zones. 
• The no-action relief, which expires no later than June 30, 2013, applies where the agent informs the reporting counterparty of the identities of its counterparties within 48 business hours (measured in the reporting counterparty's location) following execution of the swap, plus an additional 24 business hours for each day of legal holiday in the agent's jurisdiction during such period. 
• The no-action letter also provides that the reporting obligations of the reporting counterparty under Regulation 45.3(e) remain unchanged b y the no-action relief for agents.