The Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight of the Commodity Futures Trading Commission have issued relief from certain recordkeeping obligations for persons that are not registered with the CFTC in any capacity but which are members of a swap execution facility (SEF) or designated contract market (DCM). Specifically, the no-action letter provides relief to such SEF and DCM members from the requirement to record text messages and the requirement under CFTC Regulation 1.35 to keep other records in a form and manner identifiable and searchable by transaction.As provided in the no-action letter, the relief will remain effective until the CFTC takes any final action relating to this matter. 

The no-action letter is available here.