Gemini Titan LLC (“Titan”) and Gemini Olympus, LLC (“Olympus”) request a no-action position, on their own behalf and on behalf of their participants, from the swap data reporting and recordkeeping requirements of regulations 38.8(b), 38.10, 38.951 (to the extent that regulation 38.951 requires compliance with Part 45 of the Commission’s regulations), 39.20(b)(2), along with Parts 43 and 45 of the Commission’s regulations. Titan and Olympus request a no-action position with respect to reporting contracts with a binary payout structure and contracts with a variable payout structure with the features described in the letter, traded and cleared pursuant to Titan and Olympus’s rules.