Given that an SD or MSP could partially comply with Regulation 23.504 by establishing and maintaining the required written policies and procedures, the Division has determined to grant only part of the relief requested. In addition, the Division is persuaded by the requesters that its no-action relief would best be structured by counterparty type to rapidly achieve compliance for a large volume of Covered Transactions while providing appropriate relief to the SDs, MSPs and counterparties that need more time to establish documentation compliant with Regulation 23.504. Accordingly, the Division will not recommend that the Commission take an enforcement action against an SD or MSP for failure to execute swap trading relationship documentation with a counterparty in compliance with Regulation 23.504 until (1) September 1, 2013 with respect to a counterparty that is an active fund; or (2) December 31, 2013 with respect to any other counterparty except a registered SD or MSP.