The Division of Swap Dealer and Intermediary Oversight took a no-action position with respect to IBs guaranteed by a certain FCM, where the IBs would introduce ECP swap counterparties to each other, without opening or carrying customer accounts with the guarantor FCM. For uncleared swaps, no FCM would be involved in the transaction, and for cleared swaps, each counterparty would use an FCM for clearing that the counterparty had selected. The guarantor FCM would remain well-capitalized for the risk undertaken, and would be jointly and severally liable for all obligations of each of the guaranteed IBs with respect to their solicitation of swaps orders.