CFTC Staff Letters

Time-Limited No-Action Relief: Request that Certain Swaps Not Be Considered in Calculating Aggregate Gross Notional Amount for Purposes of the Swap Dealer (“SD”) De Minimis Exception for Persons Engaging in Floor Trader Activities.

Extension of Time-Limited No-Action Relief for Swap Dealers and Major Swap Participants from the Reporting Requirements of Part 45 for CDS Clearing-Related Swaps.

Additional Time-Limited No-Action Relief for Bespoke or Complex Swaps from Certain Swap Data Reporting Requirements of Parts 43 and 45 of the Commission’s Regulations.

Extension of Time-Limited No-Action Relief for Swap Dealers and Major Swap Participants from Compliance with Reporting Obligations Under 17 CFR 45.4(b)(2)(ii).

No-Action Relief: Swaps Intended to be Cleared - Request for relief from certain disclosure and notice requirements and other duties imposed on swap dealers (SDs) and major swap participants (MSPs) pursuant to Commission regulations 23.402, 23.430, 23.431, 23.432, 23.434, 23.440, 23.450, and 23.451, as well as certain documentation requirements imposed on SDs and MSPs pursuant to Commission regulation 23.504.

Request for Time-Limited No-Action Relief for Certain Swap Dealers from Compliance with Requirements of Commission Regulation 3.3 Relating to Annual Reports by Chief Compliance Officers.

The Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter stating that it will not recommend an enforcement action against an SD or MSP that omits certain "Excluded Data Fields" from the portfolio reconciliation process required under Regulation 23.502.

Extension of Time-Limited No-Action Relief from the Clearing Requirement for Swaps Entered into by Cooperatives.
The Division is extending the relief provided in the June 7 No-Action Relief until July 19, 2013. Accordingly, the Division will not recommend that the Commission commence an enforcement action against a person for failure to comply with the requirement under section 2(h)(1)(A) of the CEA and part 50 of the Commissions regulation to clear a CDS or interest rate swap subject to required clearing in 50.4 of the Commissions regulations.

No-Action Relief: Alternative to Fingerprinting to Establish Fitness of Associated Persons Residing Outside the United States.

Staff No-Action Relief: Extension of the Regulatory Status Quo Established with Respect to Certain Transactions by the Commission’s Second Amendment to the July 14, 2011 Order for Swap Regulation.