On December 19, 2016, the Commodity Futures Trading Commission (the “Commission”) issued limited no-action relief for reporting obligations for certain cleared swaps under Part 45 of the Commission’s Regulations. The no-action relief is subject to certain conditions. One such condition is that reporting entities, when submitting swaps for clearing, submit the unique swap identifier (“USI”) of the original swap and the legal entity identifier (“LEI”) of the Swap Data Repository (“SDR”) to which the original swap was reported.
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