Key takeaways

• The CFTC has granted conditional no-action relief to entities that are neither swap dealers nor major swap participants ("end-users") from certain reporting requirements under Parts 45 and 46 of the CFTC regulations and the reporting requirements related to the end-user exception from clearing under section 50.50(b), for certain inter-affiliate swaps.
• This conditional no-action relief applies to swaps between affiliates within the same corporate group that are not required to be cleared or that are required to be cleared but for which the parties may elect the end-user exception from clearing.
• Additionally, the CFTC has extended the date by which end-users must begin complying with the applicable swap data reporting requirements in Parts 43, 45 and 46 of the CFTC regulations. The applicable compliance date depends on the class of swap being reported and whether the reporting party is a financial entity.