DCR is extending the relief provided by CFTC Letter No. 20-13 and will not recommend that the Commission take enforcement action against the European Stability Mechanism (ESM) for failure to comply with the swap clearing requirement until the earlier of: (i) December 31, 2020, at 11:59 pm (Eastern Time); or (ii) the effective date of final Commission action applicable to swaps entered into by ESM that would otherwise be subject to the Commission’s clearing requirement. For the avoidance of doubt, DCR confirms that swaps entered into by ESM in reliance on the relief provided under CFTC Letter No. 17-58 may continue to rely on such relief. Other than with respect to such swaps, this letter supersedes the no-action relief provided to ESM by DCR under CFTC Letter Nos. 17-58, 19-23 and 20-13. This letter does not provide relief from other provisions of the CEA and Commission regulations, such as the recordkeeping and reporting requirements under parts 23 and 45 of the Commission’s regulations, which would apply to a non-cleared swap entered into by ESM opposite a counterparty that is subject to the CEA and Commission regulations with regard to that transaction.