On November 26, CFTC issued a no-action letter providing additional relief for eligible treasury affiliates that enter into swaps that are subject to the clearing requirement in section 2(h)(1) of the Commodity Exchange Act...more
The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief to non-US persons that are not guaranteed or conduit affiliates of US persons (Non-Guaranteed Non-US...more
Broc Romanek of TheCorporateCounsel.net recently described a member’s concerns that some companies were having on relying on the Dodd-Frank Act’s exemption for end-users for swaps entered into by treasury subsidiaries and...more