The Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight issued time-limited no-action relief with respect to some of the recordkeeping requirements under Regulation 1.35(a). The letter extends and expands the relief provided in CFTC Staff Letter No. 14-60 by relieving CTAs from the requirement to record oral communications under Regulation 1.35(a). The letter also provides relief for market participants from the requirement to link records of oral and written communications that lead to the execution of a transaction with any particular transaction.

Time-Limited No-Action Relief for Certain Members of Swap Execution Facilities from the Requirement to Record Oral Communications Pursuant to Commission Regulation 1.35(a).

No-action relief for certain branch office operations of CHS Hedging, Inc. and MID-CO Commodities, Inc. with regard to the oral recording requirements of Regulation 1.35(a)(1).

The Division of Clearing and Intermediary Oversight (Division) denied a request for relief from the requirement that an introducing broker (IB) provide specific customer account identifiers to the IB’s clearing futures commission merchant at or prior to the time of order entry. The Division found insufficient as grounds for the requested relief the requester’s assertion that compliance with the requirement would result in price “slippage” and poor customer order fills.