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Staff is considering recommending that the Commission codify the no-action relief in CFTC Staff Letters Nos. 17-31, 17-32, 21-11, and 24-09 concerning failure to comply with Commission regulations 38.8(b), 38.10, 38.951 (only to the extent that regulation 38.951 requires compliance with Part 45 of the Commission’s regulations), 39.20(b)(2), as well as the applicable provisions of Parts 43 and 45 of the Commission’s regulations, or the requirements of the relevant Commodity Exchange Act provisions pursuant to which the relevant regulations were promulgated, with respect to the reporting of fully-collateralized binary options to a swap data repository.