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.