No action relief for DCMs relating to trading floor closure in connection with the COVID-19 pandemic response.

DMO will not recommend that the Commission take an enforcement action against any SEF or SEF CCO for failure to submit an ACR within the 60-day period prescribed in Commission regulation 37.1501(f)(2), provided that: (a) the ACR was required to be submitted to the Commission prior to September 1, 2020, pursuant to Commission regulation 37.1501(f)(2); and (b) the ACR is submitted to the Commission not later than 120 days after the end of the SEF’s fiscal year.

Subject to the conditions specified in the letter, DMO will not recommend that the Commission take an enforcement action against any SEF for the failure to comply with Commission regulations 37.205(a)-(b), 37.400(b), 37.406, 37.1000(a)(1), and 37.1001 to the extent that non-compliance arises from the inability of SEFs to record voice communications as a result of the displacement of voice trading personnel from their normal business sites in connection with the COVID-19 pandemic response.

This relief revises CFTC Staff No-Action Letter 17-27 with respect to the error correction process for cleared erroneous swaps.

No-action relief from the trade execution requirement to facilitate an orderly transition from the inter-bank offered rates to alternative risk-free rates.

Granting time-limited no-action relief to [“A”] permitting its Irish bank subsidiary, [“B”], to act as reporting counterparty for [“B”]’s swaps with U.S. persons that are not swap dealers (“SDs”) or major swap participants (“MSPs”), notwithstanding the allocation of reporting responsibility set forth in Commission Regulation 45.8(e).

Extension of no-action relief granted in CFTC Letter No. 17-37, which granted relief from compliance with certain position aggregation requirements in Commission Regulation 150.4.

This staff letter ensures that existing regulatory relief provided by DSIO, DMO, and DCR pursuant to certain existing staff letters affecting EU entities continues to be available for UK entities following Brexit.

No-action relief granted to ensure the continued availability, following Brexit, of regulatory relief 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.

This no-action letter provides relief from compliance with certain position aggregation requirements under Commission Regulation 150.4.