25-13

Title: 25-13

File Link
/csl/25-13/download






Description
This staff advisory provides guidance on the materiality or other criteria that the Commodity Futures Trading Commission’s Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight will use to determine whether to make a referral to the Division of Enforcement (“DOE”) for self-reported violations, or supervision or non-compliance issues. This guidance furthers the implementation of DOE’s recent advisory, issued February 25, 2025, addressing its updated policy on self-reporting, cooperation, and remediation.

25-12

Title: 25-12

File Link
/csl/25-12/download






Description
No-action positions in relation to the Commission’s swap clearing and uncleared swap margin requirements in connection with a court-supervised transfer, pursuant to the laws of the United Kingdom, of certain legacy swaps from Credit Suisse International to UBS AG London Branch following the merger of UBS Group AG and Credit Suisse Group AG.

25-11

Title: 25-11

File Link
/csl/25-11/download






Description
UST ETFs that fall within the scope of the regulatory framework set forth in SEC Rule 6c-11 may qualify as eligible IM collateral as defined in the CFTC Margin Rule, provided the funds meet the criteria listed in Commission Regulation 23.156(a)(1)(ix). CSEs may collect or post UST ETFs that qualify as IM under Commission Regulation 23.156(a)(1)(ix) as VM for uncleared swap transactions with financial end users consistent with Commission Regulation 23.156(b)(1)(ii).

25-10

Title: 25-10

File Link
/csl/25-10/download






Description
Joint MPD and DMO interpretation providing the Divisions’ views on the characterization of certain FX transactions as being swaps, foreign exchange forwards, or foreign exchange swaps, in each case, as defined in the Commodity Exchange Act and Commission Regulations. Specifically, the Divisions state their view that: Window FX Forwards, as described in the letter, should be considered to be “foreign exchange forwards;” and Package FX Spot Transactions, as described in the letter, should not be considered to be foreign exchange swaps or swaps.

25-09

Title: 25-09

File Link
/csl/25-09/download






Description
No-action position for swap dealers and major swap participants relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission Regulation 23.431(a)(3)(i).

25-06

Title: 25-06

File Link
/csl/25-06/download






Description

Staff Interpretation allows Japanese nonbank swap dealers subject to the Japanese Comparability Order to file with the CFTC and the NFA certain enumerated schedules (the ""In Scope Schedules"") of the Annual Report to comply with condition 9 of the order. Japanese nonbank swap dealers may, but are not required to, submit the Annual Report in its entirety to comply with condition 9.

25-04

Title: 25-04

File Link
/csl/25-04/download






Description
The conditional no-action position with respect to Regulation 39.13(g)(8)(iii) contained in CFTC Letter No. 19-17 is now further extended until July 21, 2025.

24-13

Title: 24-13

File Link
/csl/24-13/download






Description

Extension of Time-Limited No-Action Position for Certain Foreign Based Nonbank Swap Dealers Domiciled in the European Union and the United Kingdom

24-11

Title: 24-11

File Link
/csl/24-11/download






Description

Extension of no-action position in 22-16 issued to ensure the continued availability, following Brexit, of no-action positions under certain existing CFTC comparability determinations and exemption orders originally issued by the CFTC for EU entities, while CFTC staff undertakes an analysis of UK law in order to make appropriate recommendations of comparability or exemption to the CFTC.

24-07

Title: 24-07

File Link
/csl/24-07/download






Description

Accordingly, the conditional no-action position with respect to Regulation 39.13(g)(8)(iii) contained in CFTC Letter No. 19-17 is now further extended until the earlier of (a) June 30, 2025 or (b) the effective date of any final Commission action relating to the Second Proposal.

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