CFTC No-Action Letter on Pay-to-Play Rules for Swap Dealers

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On November 20, the CFTC issued a no-action letter on pay-to-play rules for swap dealers who conduct business with governmental special entities. The rules restrict a swap dealer from engaging in certain activities with a governmental special entity if the swap dealer (or covered associate) made or solicited contributions to an official of that governmental special entity during the preceding two years. The no-action letter provides relief for certain contributions. CFTC Release. No-Action Letter.


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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