CFTC Market Oversight is implementing a new large trader reporting system for physical commodity swaps and swaptions (a 'swap option').  Clearing organizations and clearing members ("market participants") must comply with the new reporting requirements according to the following staggered start dates:  

• On 11/21/11. Begin reporting under the new system.
• By 3/20/12. Submit to CFTC fully compliant month-end open interest reports for September 2011 through February 2012.

Because this is the 1st time that swaps data is being collected on a systematic basis, market participants have been given a temporary and conditional safe harbor for less-than-fully-compliant reporting while Market Oversight Division launches its XML-based large trader reporting system for swaps. Here are the conditions:

• Safe harbor available only for market participants making a good faith effort to comply with the new rules.  The temporary relief is intended to provide the industry and the CFTC to transition to fully-compliant reporting by 3/20/12.

• Participants relying on the safe harbor also must submit an e-mail to the Division for its review that includes information on arrangements being made to come into full compliance with the rules, as well as the expected date of such compliance.

For further details, go to:   [CFTC PR Release 6144-11, 11/18/11]  and   [CFTC Large Trader Reporting Program page]