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

Withdrawal of staff advisory and no-action relief: transaction-level requirements for non-U.S. swap dealers

Proper reporting of swaps is an important obligation of SDs and MSPs. Firms should ensure that they have the systems and controls to properly report and to timely identify and correct any errors. Firms should periodically test their systems to ensure that the information is being properly transmitted. Further, any changes in systems that could have an effect on proper reporting should be tested and verified prior to any such changes.

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.

Time-limited no-action relief for Non-U.S. SDs with respect to compliance with Transaction-Level Requirements when entering into Covered Transactions, until January 14, 2014.