On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter extending the relief provided by CFTC Letter No. 14-01. Pursuant to this relief, the DSIO will not recommend enforcement action against a non-US swap dealer that uses personnel or agents located in the United States to arrange, negotiate or execute certain swaps with non-US persons for failing to comply with the transaction-level requirements, provided the non-US persons are not guaranteed affiliates or conduit affiliates of a US person. This relief will now be available until December 31.
The no-action letter is available here.