CFTC No-Action Relief for Certain Swap Transactions

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On December 6, the CFTC issued a no-action letter that provides swap dealers and major swap participants with relief from the requirement to disclose the pre-trade mid-market mark to counterparties in certain foreign exchange transactions under Regulation 23.43. CFTC Release. CFTC No-Action Letter.

On November 30, the CFTC issued a time limited no-action letter granting relief for bespoke or complex swaps from certain reporting obligations. CFTC Release. CFTC No-Action Letter.

 

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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.

© Orrick - Structured Finance Group | Attorney Advertising

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