No-action position for registered swap dealers and major swap participants that enter into certain swaps referencing the Secured Overnight Financing Rate (described in the letter) relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission regulation 23.431(a)(3)(i).

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.