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CFTC Staff Issues Supplemental Letter Regarding No-Action Position On Reporting, Recordkeeping Requirements

Date 01/05/2026

The Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk today announced they have taken a no-action position regarding swap data reporting and recordkeeping regulations. 

The divisions will not recommend the Commission initiate an enforcement action against Gemini Titan, LLC, a designated contract market, and Gemini Olympus, LLC, a derivatives clearing organization, or their participants for failure to comply with certain swap-related recordkeeping requirements; and for failure to report to swap data repositories data associated with contracts with a binary payout structure and contracts with a variable payout structure executed on or subject to the rules of Titan and cleared through Olympus. This no action position is subject to the terms of the no-action letter issued today. 

This position is in response to a request from Titan and Olympus to supplement CFTC Letter No. 25-44 to cover transactions cleared through Olympus.

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