DSIO Issues Time-Limited, Conditional No-Action Relief for Excluding Certain Loan-Related Swaps from Counting toward the Swap Dealer Registration De Minimis Threshold

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On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (“DSIO“) announced “conditional, time-limited no-action relief to a banking entity for not counting certain loan-related swaps towards its swap dealer de minimis threshold (under paragraph (4) of the “swap dealer” definition in Regulation 1.3).”  The specific conditions are provided in the letter and apply to specific swaps between “the date of the no-action relief through December 31, 2018.” Press Release.

 

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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