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.