Revision of CFTC Staff Letter No. 13-70, regarding certain duties imposed on swap dealers (SDs) and major swap participants (MSPs) pursuant to the Commission’s Business Conduct Standards with Counterparties, as well as certain documentation requirements imposed on SDs and MSPs pursuant to Commission regulation § 23.504 for Intended-To-Be-Cleared Swaps.

MPD is providing relief to swap dealers from registration de minimis requirements, uncleared swap margin rules, business conduct requirements, confirmation, documentation, and reconciliation requirements, and certain other eligibility requirements. This relief is to help facilitate the orderly transition from swaps that reference the London Interbank Offered Rate (LIBOR) and other interbank offered rates to swaps that reference alternative benchmarks. (ARRC No-Action Relief Extension Request)

Brexit-related time limited no-action position with respect to certain swap dealer transaction-level requirements

DSIO is providing relief to swap dealers from registration de minimis requirements, uncleared swap margin rules, business conduct requirements, confirmation, documentation, and reconciliation requirements, and certain other eligibility requirements. This relief is to help facilitate the orderly transition from swaps that reference the London Interbank Offered Rate (LIBOR) and other interbank offered rates to swaps that reference alternative benchmarks.

No-action relief to facilitate an orderly transition of swaps from inter-bank offered rates to alternative benchmarks.

Advisory clarifying that no documentation concerning the collection, posting and custody of initial margin is required to be completed until the initial margin threshold amount of $50 million has been exceeded.

Conditional no-action relief related to CFTC No-Action Letter No. 15-29 with respect to swaps trading on Yieldbroker Pty Limited

Wells Fargo requests no-action relief permitting the London Branch and its counterparties to comply with the relevant requirements applicable to its Foreign Clients in lieu of the Commissions Transaction-Level Requirements. Wells Fargo requests the no-action relief only with respect to swaps between the London Branch and its Foreign Clients. Based on the foregoing and the representations made by Wells Fargo, the Divisions believe that granting no-action relief is warranted.

No-Action Relief is provided to swap dealers from compliance with certain Commission regulations related to business conduct standards with counterparties and swap trading relationship documentation when entering into swaps with certain special purpose vehicles in existence prior to October 10, 2013.

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