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Washington, D.C. — The Commodity Futures Buying and selling Fee’s Division of Market Oversight (DMO) and Division of Information (DOD) as we speak issued a workers no-action letter concerning sure Half 43 and Half 45 swap reporting obligations for swaps transitioning below the ISDA LIBOR fallback provisions from referencing the remaining tenors of USD LIBOR, in addition to USD LIBOR ICE Swap Charges and Moscow Prime Provided Price (collectively, the Impacted Charges), to referencing risk-free charges (RFRs) following the cessation or non-representativeness of the Impacted Charges on June 30, 2023.
The letter states DMO and DOD won’t advocate the CFTC take enforcement motion in opposition to an entity for failure to well timed report below Half 45 the change in a swap’s floating charge. This letter covers these floating charge modifications which might be made below the ISDA LIBOR fallback provisions from Impacted Charges to the relevant RFR, however solely within the occasion the entity makes use of its greatest efforts to report the change by the relevant deadline in Half 45 and in no case stories the required info later than 5 enterprise days from, however excluding, June 30, 2023.
The letter additionally states DMO and DOD won’t advocate the CFTC take enforcement motion in opposition to an entity for failure to report below Half 43 the change within the floating charge for a swap modified after execution to include the ISDA LIBOR fallback provisions to transition from referencing any Impacted Price to referencing an RFR.
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