CFTC Issues No-Action Relief for Event Contracts, Exempting DCMs and DCOs From Swap Reporting Rules

TLDR:

• CFTC’s Division of Market Oversight and Division of Clearing and Risk issued no-action relief on May 13, 2026.
• DCMs, DCOs, and market participants are exempt from swap recordkeeping and swap data repository reporting rules.
• The no-action position covers all beneficiaries of previous no-action letters for fully collateralized event contracts.
• A streamlined process now allows new applicants to request identical relief and be added to the no-action letter appendix.

The Commodity Futures Trading Commission has issued no-action relief for fully collateralized event contracts. The relief exempts designated contract markets, derivatives clearing organizations, and market participants from certain swap recordkeeping and reporting requirements.

The CFTC’s Division of Market Oversight and Division of Clearing and Risk announced the position on May 13, 2026. The agency also introduced a streamlined process for future applicants.

CFTC Divisions Announce No-Action Position on Swap Data Reporting

The two CFTC divisions will not recommend enforcement action against DCMs, DCOs, or their participants. Specifically, the relief covers failure to comply with swap-related recordkeeping requirements. It also covers failure to report event contract transaction data to swap data repositories.

This no-action position came in response to numerous requests from DCMs and DCOs that list and clear event contracts.

Those entities had sought relief from reporting obligations tied to fully collateralized event contract transactions. The divisions reviewed these requests and determined a broader, uniform response was warranted.

The official release confirmed that “this no-action position is subject to the terms of the no-action letter issued today.” The no-action position is subject to the specific terms outlined in the letter issued on May 13.

Market participants should review those terms carefully before relying on the relief. The letter sets the boundaries within which the position applies.

Streamlined Process Introduced for Future Event Contract Applicants

The divisions also anticipate receiving similar requests going forward. These include requests to modify previous no-action positions due to DCM designation order amendments and changes in DCOs. To address this, the agency introduced a more efficient process for handling such requests.

The CFTC stated that “the divisions intend for today’s no-action position to streamline the process for addressing such requests and to ensure uniform treatment of market participants.”

Today’s no-action position covers all beneficiaries of previous no-action letters for similar contracts. Entities wishing to list or clear comparable contracts may request a no-action position identical to the one issued.

The agency further clarified that “this approach removes the need for the divisions to continually issue identical no-action letters and ensures consistent treatment for new and previous applicants.”

If a request is granted, the divisions will add the requester to an appendix attached to the no-action letter. The streamlined process reflects the agency’s effort to reduce administrative burden while maintaining regulatory oversight. Market participants in this space now have a more defined path for seeking similar relief.

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