CFTC Extends No-Action Relief for Certain Transaction-Level Requirements for Non-US Swap Dealers

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter extending the relief provided by CFTC Letter No. 14-01. Pursuant to this relief, the DSIO will not recommend enforcement action against a non-US swap dealer that uses personnel or agents located in the United States to arrange, negotiate or execute certain swaps with non-US persons for failing to comply with the transaction-level requirements, provided the non-US persons are not guaranteed affiliates or conduit affiliates of a US person. This relief will now be available until December 31. 

The no-action letter is available here.

 

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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