US Commodity Futures Trading Commission Staff Extends Time-Limited No-Action Relief on the Applicability of Transaction-Level Requirements in Certain Cross-Border Situations

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The U.S. Commodity Futures Trading Commission’s (CFTC) Divisions of Swap Dealer and Intermediary Oversight (DSIO), Clearing and Risk, and Market Oversight issued a time-limited no-action letter providing relief to certain CFTC-registered swap dealers (SDs) that operate outside of the United States (Non-U.S. SDs) from specific transaction-level requirements pursuant to the Commodity Exchange Act.

The letter sets forth certain limitations and the relief is subject to the effective date of CFTC action determining which transaction-level requirements are applicable to certain swaps between non-U.S. SDs and their U.S. counterparts. This relief comes as a result of compliance issues raised by a DSIO-issued advisory on November 14, 2013 regarding applicability of the CFTC’s transaction-level requirements in certain circumstances.

View CFTC Staff Letter 17-36.

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. Attorney Advertising.

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