CFTC Staff Letters

Extension of No-Action Relief: Transaction-Level Requirements for Non-U.S. Swap Dealers

Extension of conditional time-limited no-action relief for Yieldbroker Pty Limited with regard to Section 5h(a)(1) of the Commodity Exchange Act and Commission Regulation 37.3(a)(1) until February 15, 2015.

No-action relief and interpretation of certain aspects of Regulation 30.7 with respect to the holding of customer funds in accounts located outside of the U.S.

The Division previously provided no-action relief for certain swaps required to be traded on a swap execution facility (SEF) or designated contract market (DCM) to the extent that those swaps were part of a package transaction. The Division has determined that further relief is appropriate to enable market participants to fully comply with the trade execution requirement with respect to swap components of certain categories of package transactions.

The Division of Market Oversight is extending the relief provided in CFTC Letter No. 14-26 for one year, until December 31, 2015. The letter provides no-action relief from the trade execution requirement of Commodity Exchange Act section 2(h)(8) to eligible affiliate counterparties, as defined in section 50.52(a) of the Commission’s regulations.

No-action letter again extending the time-limitation contained in an alternative compliance framework available to certain affiliated counterparties pursuant to Commission regulation 50.52(b)(4)(ii)-(iii).

Time-limited no-action relief to allow Southwest Airlines and its counterparties additional time for public reporting of long-dated Brent and WTI crude oil swap and swaption contracts executed by or with Southwest Airlines.

The Division of Swap Dealer and Intermediary Oversight issued a “no-action” position from compliance with certain requirements of Regulation 1.57(a)(1), such that a guaranteed introducing broker could open and carry customer accounts with other than its guaranteeing futures commission merchant. Among other things, customers would be eligible contract participants and it was anticipated that the ultimate owner of the guaranteeing futures commission merchant would be the ultimate owner of an interest in the guaranteed introducing broker.

Staff interpretation regarding notification of the right to segregation of initial margin in uncleared swap transactions and quarterly reporting under Commission Regulations 23.701 and 23.704

Extension of no-action relief from compliance with certain conditions associated with the receipt of customer funds by FCMs.