Currently Effective Staff Letters

The Commodity Futures Trading Commission is in the process of implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Staff of the CFTC is in the process of responding to staff no-action letters regarding rules issued under Dodd-Frank.

View Dodd-Frank Final Rules and Orders
View Dodd-Frank Proposed Rules
View all Dodd-Frank Guidance, Advisories and Questions and Answers
Expired Dodd-Frank Staff No-Action Letters

Currently effective staff no-action letters

Publication
Date

Letters

12/02/2022

Supplemental Staff Letter to CFTC Letter15-29 and CFTC Letter 16-72 with respect to swaps trading on certain financial markets that are licensed in Australia and overseen by the Australian Securities & Investments Commission (ASIC).
See also: Request Letter; Requester(s): YIELDBRKER
Regulation Parts: 43, 45; No-Action
22-19

12/02/2022

Extension of no-action position with respect to Part 45 for entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating consistent with CFTC exemptive orders or no-action positions provided by CFTC staff.
See also: Request Letter; Requester(s): ISDA
CFTC Regulation Part: 45; No-Action
22-18

08/17/2022 Extension of Time-Limited No-Action Position for Foreign Based Nonbank Swap Dealers domiciled in Japan, Mexico, the United Kingdom, and the European Union
See also: Request Letter; Requester(s): IIB, ISDA, SIFMA
CFTC Regulation Parts: 23, 23 Subpart E, 23.100, 23.101, 23.102, 23.103, 23.104, 23.105, 23.106; No-Action
22-10
08/10/2022 Extension of no-action relief granted in CFTC Staff Letter No. 19-19, which granted relief from prospective compliance with certain position aggregation requirements in Commission Regulation 150.4. Requester(s): FIA, MFA, SIFMA AMG
CFTC Regulation Parts: 4150.2, 150.4; No-Action
22-09
01/31/2022 DOD is taking a time-limited no-action position with respect to the compliance dates for the November 25, 2020 amendments to certain of the swap data reporting rules in Parts 43, 45, 46, and 49.
See also: Request Letter; Requester(s): CMESDR, DTCC, ICE SDR, ISDA
CFTC Regulation Parts: 43, 45, 46, 49; No-Action
22-03
01/05/2022 No-Action Relief permitting certain Foreign-Based SD to File Annual Financial Reports pursuant to Regulation 23.105(e) in Accordance with Singapore Financial Reporting Standards (Morgan Stanley - J. Aron Singapore Accounting No-Action Relief Request)
CFTC Regulation Parts: 23.105; No-Action
22-02
01/05/2022 No-Action Position for Foreign-Based SD to File Annual Financial Reports in Accordance with Australian Accounting Standards Board (Goldman Sachs No-Action Relief Request)
CFTC Regulation Parts: 23.105; No-Action
22-01
12/22/2021 DOD is taking a no-action position with respect to certain Part 43 and Part 45 swap reporting obligations for swaps transitioning under the ISDA LIBOR fallback provisions from referencing certain London Interbank Offered Rates (LIBORs) to referencing risk-free rates (RFRs) following the cessation or non-representativeness of those LIBORs on December 31, 2021. (ARRC No-Action Relief Request)
CFTC Regulation Parts: 43.3, 45.4; No-Action
21-30
09/30/2021 Letter of Non-Compliance and related Temporary No-Action Position for StoneX Markets LLC with regard to Certain Capital Requirements (SXM No-Action Request)
CFTC Regulation Parts: 23.101, 23.102; No-Action
21-23
09/30/2021 Time-Limited No-Action Position for Registered Swap Dealer to use Models to Compute Market Risk and Credit Risk Capital Charges In Lieu of Standardized Charges (JFSI No-Action Request)
CFTC Regulation Parts: 23.102, 23.103; No-Action
21-22
08/31/2021 Time Limited No Action relief from regulation 23.105(p) for certain alternative financial reporting by SDs subject to the capital requirements of a prudential regulator.
CFTC Regulation Parts: 23.105; No-Action
21-18
06/29/2021 Advisory to SDs indicating they are not required to obtain approval to use a model to calculate the initial margin on uncleared swaps for purposes of determining the SD’s minimum capital requirement under Commission regulations.
CFTC Regulation Parts: 1.17, 23.100, 23.101, 23.102; No-Action
21-15
06/22/2021 Advisory to SDs indicating they are not required to obtain approval to use a model to calculate the initial margin on uncleared swaps for purposes of determining the SD’s minimum capital requirement under Commission regulations.
CFTC Regulation Parts: 1.17, 23.100, 23.101, 23.102; No-Action
21-14
04/28/2021 Relief under Parts 43 and 45 to entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating under CFTC exemptive orders or no-action relief provided by CFTC staff.
CFTC Regulation Parts: 43, 45; No-Action
21-12
04/22/2021 Relief from Part 43 and 45 reporting, as well as related sections of Parts 38 and 39, for binary options executed on or pursuant to the rules of Kalshi and cleared through LedgerX.
CFTC Regulation Parts: 38.8, 38.10, 38.951, 39.20, 43, 45; No-Action
21-11
04/07/2021 Brexit-related time limited no-action position with respect to certain swap dealer transaction-level requirements.
CFTC Regulation Parts: 2(h)(8), 23, 23.202, 23.205, 23 Subpart I, 23.500, 23.501, 23.502, 23.503, 23.504, 23.505, 23.506, 23.610, 23 Subpart L, 23.700, 23.701, 23.702, 23.703, 23.704, 37, 38, 43, 50; No-Action
21-09
01/19/2021 No-action positions for floor brokers and introducing brokers from oral recordkeeping requirements and designated contract markets from audit trail requirements in continued response to the COVID-19 pandemic.
CFTC Regulation Parts: 5(d)(4), 5(d)(10), 1.35, 38.250, 38.251, 38.252, 38.253, 38.254, 38.255, 38.256, 38.553; No-Action
21-04
01/12/2021 Approval letter issued to the National Futures Association with regard to Swap Dealer capital model requirements and review program.
CFTC Regulation Parts: 23 Subpart E, 23 Subpart I; No-Action
21-03
12/04/2020 No-action letter permitting market participants to transfer certain swaps to an affiliate without such swaps becoming subject to the Commission’s swap clearing requirement or uncleared swap margin requirements in relation to the end of Brexit transition period.
CFTC Regulation Parts: 2(h), 2(h)(1), 23.150 - 23.161, 50 Subpart A, 50.4; No-Action
20-42
11/30/2020

Extension of No-Action Relief for Swap Execution Facilities from certain timing requirements for submission of fiscal-year end reports.
CFTC Regulation Parts: 37.1306, 37.1501; No-Action
20-41

11/24/2020 This MPD staff letter ensures that existing regulatory relief provided by DSIO pursuant to letters 12-70 and 13-45 affecting EU entities continues to be available for UK entities following the completion of Brexit.
CFTC Regulation Parts: 4d, 4m, 23 Subpart I, 23.502; No-Action
20-40
11/24/2020 Extension of no-action relief 19-08 granted to ensure the continued availability, following completion of Brexit, of regulatory relief under certain existing CFTC comparability determinations and exemption orders originally issued by the CFTC for EU entities.
CFTC Regulation Parts: 2(h)(8), 5h(a)(1), 23 Subpart F, 23 Subpart I, 23 Subpart J, 37.3; No-Action
20-39
11/19/2020 Time-limited no action relief for DTCC SDR and registered entities and swap counterparties reporting swaps to DTCC SDR from certain portions of Part 45, 46 and 49 of the Commission's regulations.
CFTC Regulation Parts: 45, 46, 49; No-Action
20-38
10/13/2020

Relief from the Part 43 public reporting requirements for relevant swaps related to the CME Inc SOFR discounting transition auction.
CFTC Regulation Part: 43.3; No-Action
20-33

10/13/2020

Relief from the Part 43 public reporting requirements for relevant swaps related to the LCH Limited SOFR discounting transition auction.
CFTC Regulation Part: 43.3
20-32

10/09/2020

Extension of No-Action Relief from Sections 2(h)(8) and 5(d)(9) of the Commodity Exchange Act and from Commission Regulations 37.3(a)(2) and 37.9 for Swaps Executed as Part of Certain Package Transactions.
CFTC Regulation Parts: 2(h)(8), 5(d)(9), 37.3, 37.9; No-Action
21-31

09/25/2020

Extension of conditional time-limited no-action relief from filing certain information for ownership and control reports required by Parts 17, 18, and 20 of the Commission’s regulations.
CFTC Regulation Parts: 17, 18, 20; No-Action
20-30

05/18/2020

No-action relief from certain Commission regulations with respect to certain warrants listed on foreign exchanges.
CFTC Regulation Parts: 23, 23.150, 23.151, 23.152, 23.153, 23.154, 23.155, 23.156, 23.157, 23.158, 23.159, 23.160, 23.161, 43, 45, 46; No-Action
20-18

03/20/2020

No-action position for excluding certain commodity swaps from inclusion in the major swap participant registration threshold calculation of an insured depository institution.
CFTC Regulation Part: 1.3; No-Action
20-10

03/18/2020

No-action positions for swap dealers to facilitate physical separation of personnel in response to the COVID-19 pandemic.
CFTC Regulation Parts: 3.3 and 23.202; No-Action
20-06

03/18/2020

No-action positions for certain members of designated contract markets and swap execution facilities to facilitate physical separation of personnel in response to the COVID-19 pandemic.
CFTC Regulation Part: 1.35; No-Action
20-02

12/18/2019

No-action relief granted to a swap dealer concerning the calculation of initial margin under Commission regulation 23.154.
CFTC Regulation Part: 23.15; No-Action
19-29

12/17/2019

No-action relief from the swap clearing requirement for amendments to legacy uncleared swaps to facilitate orderly transition from inter-bank offered rates to alternative risk-free rates.
CFTC Regulation Parts: 2(h)(1)(A), 50.2, 50.50 and 50.51; No-Action
19-28

12/17/2019

No-action relief from the trade execution requirement to facilitate an orderly transition from the inter-bank offered rates to alternative risk-free rates.
CFTC Regulation Part: 2(h)(8); No-Action
19-27

12/17/2019

No-action relief to facilitate an orderly transition of swaps from inter-bank offered rates to alternative benchmarks.
CFTC Regulation Parts: 1.3, 23.150, 23.151, 23.152, 23.153, 23.154, 23.155, 23.156, 23.157, 23.158, 23.159, 23.161, 23 Subpart H, 23.451, 23.501, 23.502, 23.504 and 23.505; No-Action
19-26

12/06/2019

Staff Time-Limited No-Action Position Regarding Application of Minimum Transfer Amount under the Uncleared Margin Rules.
CFTC Regulation Parts: 23.152 and 23.153; No-Action
19-25

12/04/2019

Advisory providing further guidance on certain requirements applicable to swap dealers, futures commission merchants, and major swap participants in connection with the preparation and submission of chief compliance officer annual compliance reports pursuant to § 3.3.
CFTC Regulation Part: 3.3; Advisories
19-24

07/09/2019

Advisory clarifying that no documentation concerning the collection, posting and custody of initial margin is required to be completed until the initial margin threshold amount of $50 million has been exceeded.
CFTC Regulation Parts: 23.154, 23.157, 23.158, 23.504 and 23.600; Advisories
19-16

06/27/2019

No-Action relief granted to registered floor traders from compliance with certain conditions in paragraph (6)(iv) of the "swap dealer" definition in CFTC regulation 1.3.
CFTC Regulation Parts: 1.3; No-Action
19-14

06/06/2019

No-action relief granted to swap dealers from the uncleared swap margin requirements under Part 23 of the Commission's regulations with respect to certain amendments to legacy swaps.
CFTC Regulation Parts: 23.150, 23.151, 23.152, 23.153, 23.154, 23.155, 23.156, 23.157, 23.158, 23.159, 23.160 and 23.161; No-Action
19-13

03/22/2019

No-Action Position for Off-SEF Swaps Executed Pursuant to Prime Brokerage Arrangements.
CFTC Regulation Part 23.431; No-Action
19-06

05/16/2018

No-Action Extension of no-action relief originally granted by DMO on December 19, 2016 to counterparties clearing swaps through derivatives clearing organizations acting under exemptive or no-action relief from certain reporting obligations for cleared swaps under Part 45 of the Commissions regulations.
CFTC Regulation Part: 1.3; No-Action
18-13

11/07/2017

No-action relief for non-U.S. persons that are neither guaranteed affiliates nor conduit affiliates of a U.S. person from the requirement to count swaps with international financial institutions towards the de minimis thresholds for the swap dealer and major swap participant definitions.  
Commodity Exchange Act Section  2(h)(1); CFTC Regulation Parts: 50.2 and 50.4; No-Action
17-59

11/07/2017

The Division of Clearing and Risk (DCR) will not recommend that the Commission take enforcement action against European Stability Mechanism (ESM) for failure to comply with the clearing requirement of Section 2(h)(1) of the Commodity Exchange Act as implemented by Commission Regulations 50.2 and 50.4.
Commodity Exchange Act Section  2(h)(1); CFTC Regulation Parts: 50.2 and 50.4; No-Action
17-58

11/07/2017

The Division of Clearing and Risk will not recommend that the Commission take enforcement action against Banco Centroamericano de Integración Económica (CABEI) for failure to comply with the clearing requirement of Section 2(h)(1) of the Commodity Exchange Act as implemented by Commission Regulations 50.2 and 50.4.
Commodity Exchange Act Section 2(h)(1); CFTC Regulation Parts: 50.2 and 50.4; No-Action
17-57

09/25/2017

Conditional time-limited no-action relief from filing certain Ownership and Control Reports (OCR) required by Parts 17, 18 and 20 of the Commission’s Regulations.
CFTC Regulations Parts: 17, 18 and 20; No-Action
17-45

08/10/2017

The CFTC’s staff grants time-limited no-action relief from certain position aggregation requirements.
Commodity Exchange Act Section 4a; CFTC Regulation Part: § 150.4; No-Action
17-37

05/30/2017

No-Action relief that extends the relief provided in Letter No. 16-58 by permitting SEFs and DCMs to address clerical or operational errors that cause a swap to be rejected from clearing.
CFTC Regulation Parts: 37.9(a)(2), 37.203, 38.152, and 38.500; No-Action
17-27

03/29/2017

No-Action relief regarding the application of Commission Regulation 75.14(a) to the provision of clearing services by an FCM to a covered fund.
CFTC Regulation Part: 75.14; No-Action
17-18

03/24/2017

The Division of Market Oversight is issuing a no-action letter that extends Letter No. 16-25 and provides relief from: (1) the requirement that a SEF obtain documents that are incorporated by reference in a confirmation issued under Commission Regulation 37.6(b) prior to issuing the confirmation; (2) the requirement that a SEF maintain such documents as records; and (3) the requirement that a SEF report terms contained in such documents that are confirmation data.
Commodity Exchange Act Section 2(h)(8); CFTC Regulation Parts: 37.6(b), 37.1000, 37.1001, 45.2, and 45.3(a); No-Action
17-17

03/10/2017

The CFTC’s Division of Market Oversight further extends time-limited, conditional masking no-action relief provided in CFTC Letters 16-03 and 16-33 permitting Part 45 and Part 46 reporting counterparties to mask legal entity identifiers, other enumerated identifiers and other identifying terms, and permitting Part 20 reporting entities to mask identifying information in certain enumerated jurisdictions, in each case subject to conditions.
CFTC Regulation Parts: 20, 45 and 46; No-Action
17-16

02/23/2017

CFTC Staff issues no-action relief to swap dealers for the timing of the posting and collection of variation margin from certain counterparties operating in Japan.
Commodity Exchange Act Section  4s(e); CFTC Regulation Parts:  23.153(a) and (b); No-Action
17-13

02/13/2017

CFTC Staff issues No-Action relief for Minimum Transfer Amount with respect to Separately Managed Accounts.
Commodity Exchange Act Section4s(e); CFTC Regulation Parts: 23.152(b)(3) and 23.153(c); No-Action
17-12

02/13/2017

CFTC Staff issues time-limited no-action relief from March 1, 2017 deadline for compliance with Regulations on Variation Margin for Uncleared Swaps.
Commodity Exchange Act Section  4s(e); CFTC Regulation; No-Action
17-11

02/06/2017

Time-Limited No-Action Relief, until 12:01 a.m. eastern standard time on August 14, 2017, from compliance with the notice filing requirements of Commission Regulation 150.4(c), as effective February 14, 2017.
CFTC Regulation Part: § 150.4(c) Aggregation Exemption Notice Filing Requirement; No-Action
17-06

02/06/2017

Time-Limited No-Action Relief, until 12:01 a.m. eastern standard time on August 14, 2017, from compliance with the notice filing requirements of Commission Regulation 150.4(c), as effective February 14, 2017.
CFTC Regulation Part: § 150.4(c) Aggregation Exemption Notice Filing Requirement; No-Action
17-06

06/10/2016 DMO and DCR are extending the relief provided in CFTC Letter No. 15-24 and enabling SEFs and DCMs to address clerical and operational errors.
CFTC Regulation Parts: 37.9(a)(2), 37.203, 38.152, and 38.500; No-Action
16-58
12/22/2015 No-action relief for swap execution facilities (“SEFs”) from certain requirements under Commission Regulation 37.205 that require SEFs to capture post-trade allocation information in their audit trail data.
CFTC Regulation Part: 37.205; No-Action
15-68
12/08/2015 Extension of relief provided in CFTC Staff Letter No. 14-147, which relieves CTAs from the requirement to record oral communications under Regulation 1.35(a) and relief for all those subject to 1.35(a) from the requirement to link records of oral and written communications that lead to the execution of a transaction with any particular transaction.
CFTC Regulation Part: 1.35; No Action
15-65
11/09/2015 The Division of Market Oversight issues time-limited no-action relief from certain requirements of Part 45 and Part 46 of the Commission’s Regulations, for certain swap dealers and major swap participants established under the laws of Australia, Canada, the European Union, Japan or Switzerland. 
CFTC Regulation Parts: 45 and Part 46; No Action 
15-61
11/02/2015 The Division of Market Oversight extended time-limited no-action relief to Swap Execution Facilities (SEFs) from certain requirements in the definition of “Block trade” in Commission regulation § 43.2. 
CFTC Regulation Part: 43.2; No Action 
15-60
10/14/2015 The Division previously provided no-action relief for certain swaps required to be traded on a swap execution facility (SEF) or designated contract market (DCM) to the extent that those swaps were part of a package transaction.  The Division has determined that further relief is appropriate to enable the Division to continue to further assess the appropriate response for applying the trade execution requirement to swaps in certain types of package transactions.   
Commodity Exchange Act Sections 2(h)(8) and 5(d)(9); CFTC Regulation Parts: §§37.9 and 37.3(a)(2); No-Action 
15-55
05/15/2015 Extension of conditional time-limited no-action relief for Yieldbroker Pty Limited with regard to Section 5h(a)(1) of the Commodity Exchange Act and Commission Regulation 37.3(a)(1) until October 15, 2015.
Commodity Exchange Act Section  5h(a)(1); CFTC Regulation Parts: 37.3(a)(1); No-Action
15-30
05/15/2015 Conditional no-action relief with respect to swaps trading on certain financial markets that are licensed in Australia and overseen by the Australian Securities & Investments Commission (ASIC). 
Commodity Exchange Act Sections 2(h)(8) and 5h(a)(1); CFTC Regulation Part: 37.3(a)(1); parts 23, 43 and 45; No-Action   
15-29
04/23/2015 The Division of Market Oversight is issuing Guidance to swap execution facilities regarding the calculation of projected operating costs or expenses for the purpose of meeting the financial resource requirements under SEF Core Principle 13 and Commission Regulation 37.1303 and clarifies that commissions paid employee-brokers, calculated as a percentage of transaction revenue, do not have to be included in the calculation.
Commodity Exchange Act Section 2(h)(8); CFTC Regulation Parts: 37.6(b), 37.1000, 37.1001, 45.2, and 45.3(a); Other Written Communication
15-26
04/22/2015 The Division of Market Oversight is issuing a no-action letter that extends No-Action Letter 14-108 and continues to provide relief from (1) the requirement that a SEF obtain documents that are incorporated by reference in confirmations issued under Commission Regulation 37.6(b) prior to issuing the confirmation, and (2) the requirement that a SEF maintain such documents as records. In addition, the division is providing relief from the requirement set forth in Commission Regulation 45.3(a) that SEFs report terms contained in the agreements that are confirmation data.
Commodity Exchange Act Section 2(h)(8); CFTC Regulation Parts: 37.6(b), 37.1000, 37.1001, 45.2, and 45.3(a); No-Action
15-25
04/22/2015 The Division of Market Oversight and the Division of Clearing and Risk are issuing a no-action letter that provides relief similar to that provided in No-Action Letters 13-66 and 14-50 by permitting swap execution facilities (SEFs) and designated contract markets (DCMs) to address clerical or operational errors that cause a swap to be rejected from clearing. The relief provided in this letter also permits SEFs and DCMS to address clerical or operational errors discovered after a swap has been cleared.
CFTC Regulation Parts: 37.9(a)(2), 37.203, 38.152, and 38.500; No-Action
15-24
01/23/2015 Request for No-Action Relief for Introducing Brokers’ Compliance with Certain Financial Reporting and Capital Computation Requirements under Regulations 1.10 and 1.17.
CFTC Regulation Parts: 1.10 and 1.17; No-Action
15-02
12/16/2014 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.
CFTC Regulation Part: 1.35(a); No-Action
14-147
11/26/2014 The Division of Swap Dealer and Intermediary Oversight granted exemptive relief from the financial statement requirements of Commission regulations 4.22 and the disclosure requirements of Commission regulation 4.24(s) to the commodity pool operator (the “CPO”) of an insurance-linked securitization vehicle (the “ILS Vehicle”) with respect to the ILS Vehicle; provided, that the CPO satisfies certain conditions for relief relating to the management of the ILS Vehicle, the disclosure of additional information concerning the ILS Vehicle, and the calculation of the net asset value of the ILS Vehicle.
Commodity Exchange Act Section  2(h)(7); CFTC Regulation Part: 50.50; No-Action
14-144
11/14/2014 Extension of No-Action Relief: Transaction-Level Requirements for Non-U.S. Swap Dealers.
CFTC Regulation Parts: 23.202, 23.205, 23.400 to 23.451, 23.501, 23.502, 23.503, 23.504, 23.505, 23.506, 23.610, 23.701 to 23.704, and parts 37, 38, 43, and 50; No-Action
14-140
11/13/2014 Extension of conditional time-limited no-action relief for Yieldbroker Pty Limited with regard to Section 5h(a)(1) of the Commodity Exchange Act and Commission Regulation 37.3(a)(1) until February 15, 2015.
Commodity Exchange Act Section  5h(a)(1); CFTC Regulation Part: 37.3(a)(1); No-Action
14-139
09/30/2014 SEFs and DCMs will have time-limited no-action relief from Commission Regulation 37.9(a)(2) regarding methods of execution for required transactions, or Commission Regulations 37.203(a) and 38.152 that prohibit pre-arranged trading, if a SEF or DCM permits a new trade, with terms and conditions that match the terms and conditions of the original trade, other than the time of execution, to be submitted for clearing. This no-action relief shall commence on the date of issuance of this letter and shall expire on February 16, 2015.
CFTC Regulation Parts: § 37.9(a)(2), § 37.203(a) and § 38.152; No-Action
14-121
09/29/2014 The CFTC’s Division of Market Oversight issued an extension of no-action letter 13-86, which provided relief in connection with certain CDS trades executed pursuant to a DCO’s CDS Settlement Price Process, providing time-limited no-action relief to DCOs and their Clearing Members from the SEF Registration Requirement and Trading Mandate under Part 37, and from various reporting requirements under Part 45, allowing the DCO to fulfill the Reporting Counterparty’s Obligations.
CFTC Regulation Part: 37 and 45; No-Action
14-119
06/27/2014 Extension of no-action relief granted by DMO on June 26, 2013 to SD and MSP reporting counterparties for cleared swaps from valuation data reporting required in section 45.4(b)(2)(ii) of the Commission’s regulations.
CFTC Regulation Parts: 20, 45 and 46; No-Action
14-89
04/25/2014 Time-Limited No-Action Relief for Certain Members of Swap Execution Facilities and Designated Contract Markets from the Requirement to Record Oral Communications, Pursuant to Commission Regulation 1.35(a), in Connection with the Execution of Swap Transactions
CFTC Regulation Part: 1.35(a); No-Action
14-60
03/06/2014 Time-Limited No-Action Relief from the Commodity Exchange Act Section 2(h)(8) for Swaps Executed Between Certain Affiliated Entities Not Electing Commission Regulation 50.52
Commodity Exchange Act Section 2(h)(8) of the Act; No-Action
14-26
12/30/2013 Time-Limited No-Action Relief for Futures Commission Merchants, Swap Dealers, and Major Swap Participants from Compliance with the Timing Requirements of Commission Regulation 3.3(f)(2) Relating to Annual Reports by Chief Compliance Officers
CFTC Regulation Part: 3.3(f); No-Action
13-84
12/23/2013 No-action relief for certain Introducing Brokers from filing certified and unaudited financial statements and calculating capital under regulation 1.17.
CFTC Regulation Part: 1.10 and 1.17; No-Action
13-82
12/20/2013 Time-Limited No-Action Letter from Certain Entity-Level Internal Business Conduct Requirements for Certain Swap Dealers and Major Swap Participants Established under the Laws of Australia, Canada, the European Union, Japan, and Switzerland.
CFTC Regulation Parts: 23.600(c)(2), 23.608, and 23.609; No-Action
13-78
11/15/2013 The Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter that provides relief for certain regulatory obligations of SDs and MSPs in the context of an “Intended-To-Be-Cleared Swap,” which, as defined in the letter, is a swap that is: (i) of a type accepted for clearing by a DCO, and (ii) intended to be submitted for clearing contemporaneously with execution. The relief extends to certain requirements under the External BCS and Commission Regulation 23.504, subject to the conditions and limitations set forth in the letter. This letter supersedes Letter No. 13-33, and states that no person may rely upon the relief provided in Letter No. 13-33 after November 15, 2013.
CFTC Regulation Parts: 23.402, 23.430, 23.431, 23.432, 23.434, 23.440, 23.450, 23.451, and 23.504, No-Action
13-70
10/17/2013 No-Action Relief: Certain Swaps by Non-U.S. Persons that are Not Guaranteed or Conduit Affiliates of a U.S. Person Not to be Considered in Calculating Aggregate Gross Notional Amount for Purposes of Swap Dealer De Minimis Exception.
CFTC Regulation Part: 1.3(ggg); No-Action
13-64
07/11/2013 Amendment to the Direct Access No-Action Letters Issued to Foreign Boards of Trade to Permit Swaps to be Listed for Trading by Direct Access.
Commodity Exchange Act Section  5 and 5a; No-Action
13-46
07/11/2013 No-Action Relief for Registered Swap Dealers and Major Swap Participants from Certain Requirements under Subpart I of Part 23 of Commission Regulations in Connection with Uncleared Swaps Subject to Risk Mitigation Techniques under EMIR.
CFTC Regulation Part: 23, Subpart I; No-Action
13-45
06/28/2013 Time-Limited No-Action Relief Permitting Part 45 and Part 46 Reporting Counterparties to Mask Legal Entity Identifiers, Other Enumerated Identifiers and Other Identifying Terms and Permitting Part 20 Reporting Entities to Mask Identifying Information, with respect to certain Enumerated Jurisdictions.
CFTC Regulation Parts: 20, 45 and 46; No-Action
13-41
06/27/2013 The Division of Swap Dealer and Intermediary Oversight issued a no-action letter that provides swap dealers with relief from certain External Business Conduct Standards rules in the context of foreign exchange intermediated prime brokerage arrangements.
CFTC Regulation Part: 23, Subpart H; No-Action
13-39
06/26/2013 The Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter stating that it will not recommend an enforcement action against an SD or MSP that omits certain "Excluded Data Fields" from the portfolio reconciliation process required under Regulation 23.502.
CFTC Regulation Part: 23.502; No-Action
13-31
06/21/2013 No-Action Relief: Alternative to Fingerprinting to Establish Fitness of Associated Persons Residing Outside the United States.
CFTC Regulation Part: 3.12; No-Action
13-29
06/10/2013 No-Action Relief for Corporación Andina de Fomento from the Swap Clearing Requirement in Section 2(h)(1) of the Commodity Exchange Act and Commission Regulations 50.2 and 50.4.
Commodity Exchange Act Section 2(h)(1); CFTC Regulation Parts: 50.2 and 50.4; No-Action
13-25
05/01/2013 Relief for Swap Dealers and Major Swap Participants Regarding the Obligation to Provide Certain Disclosures for Certain Transactions Under Regulation 23.431.
CFTC Regulation Part: 23.431; No-Action
13-12
4/30/2013 Time Limited Relief for Swap Dealers in Connection with Prime Brokerage Arrangements.
CFTC Regulation Part: 23, Subpart H; No-Action
13-11
04/05/2013 No-Action Relief for Swaps Between Affiliated Counterparties That Are Neither Swap Dealers Nor Major Swap Participants from Certain Swap Data Reporting Requirements Under Parts 45, 46, and Regulation 50.50(b) of the Commission’s Regulations.
CFTC Regulation Parts: 45, 46, and 50; No-Action
13-09
04/05/2013 Staff No-Action Relief from the Reporting Requirements of § 32.3(b)(1) of the Commission’s Regulations, and Certain Recordkeeping Requirements of § 32.3(b), for End Users Eligible for the Trade Option Exemption.
CFTC Regulation Part: 32.2, 32.3; No-Action
13-08
03/20/2013 No-Action Relief from Required Clearing for Partial Novation and Partial Termination of Swap
Commodity Exchange Act Section (h); No-Action
13-02
03/18/2013 No-Action Relief from Required Clearing for Swaps Resulting from Multilateral Portfolio Compression Exercises
Commodity Exchange Act Section  2(h); No-Action
13-01
12/31/2012 No-Action Relief: U.S. Bank Wholly Owned by Foreign Entity May Calculate De Minimis Threshold Without Including Activity From Its Foreign Affiliates.
CFTC Regulation Part: 1.3(ggg)(4); No-Action
12-71
12/31/2012 Relief for Certain Swap Dealers, De Minimis Dealers, Agent Affiliates, and Associated Persons from Registration as an Introducing Broker under Section 4d or a Commodity Trading Advisor under Section 4m of the Commodity Exchange Act, and Interpretation that Certain Employees of De Minimis Dealers are not an Introducing Broker as defined in Section 1a(31) of the Commodity Exchange Act.
Commodity Exchange Act Sections 4d and 4m; No-Action; Exemption
12-70
12/21/2012 No-Action Relief: Request that Certain Swaps Not Be Considered in Calculating Aggregate Gross Notional Amount for Purposes of the Swap Dealer De Minimis Exception for Persons Engaging in Multilateral Portfolio Compression Activities.
CFTC Regulation Part: 1.3(ggg); No-Action
12-62
12/18/2012 Request for Relief Regarding Obligation to Provide Pre-Trade Mid-Market Mark for Certain Credit Default Swaps and Interest Rate Swaps.
CFTC Regulation Part: 23.431; No-Action
12-58
12/12/2012 Relief for a CTA from Section 4m(1) of the Commodity Exchange Act.
Commodity Exchange Act Section 4m(1) – CTA registration requirement; No-Action
12-54
12/11/2012 No-Action Relief: Alternative to Fingerprinting to Establish Fitness of Principals Residing Outside the United States.
CFTC Regulation Part: 3.10(a)(2); No-Action
12-49
12/07/2012 No-Action Relief from the Commodity Pool Operator Registration Requirement for Commodity Pool Operators of Certain Pooled Investment Vehicles Organized as Mortgage Real Estate Investment Trusts.
CFTC Regulation Parts: 3 and 4; No-Action
12-44
12/07/2012 Relief for Swap Dealers and Major Swap Participants from Compliance with Regulation 23.22(b) with Respect to: (1) Non-Domestic Associated Persons who Deal only with Non-Domestic Swap Counterparties; and (2) Persons Employed in a Clerical or Ministerial Capacity.
CFTC Regulation Part: 23.22(b) – Prohibition against associating with a person subject to a statutory disqualification; No-Action
12-43
12/06/2012 Request for Relief Regarding Obligation to Provide Pre-Trade Mid-Market Mark for Certain Foreign Exchange Transactions.
CFTC Regulation Part: 23.431; No-Action
12-42
12/04/2012 No-Action Relief from the Commodity Pool Operator Registration Requirement for Commodity Pool Operators of Certain Pooled Investment Vehicles Organized as Business Development Companies.
CFTC Regulation Parts: 3 and 4; No-Action
12-40
11/29/2012 No-Action Letter: Delayed Compliance Date of Amended Part 4; Rescission of Former Appendix A.
CFTC Regulation Parts: 3 and 4; No-Action
12-38
11/29/2012 No-Action Relief related failure to register with the Commission as a CPO against a CPO that is a Family Office within the meaning and intent of 17 CFR § 275.202(a)(11)(G)-1, as amended..
CFTC Regulation Parts: 3 and 4; No-Action
12-37
11/29/2012 Requests for No-Action Relief from Commission Regulation 23.451 in Connection with Dealings with Certain Governmental Plans and for Clarification Concerning the “Look-Back” Provision of Commission Regulation 23.451.
Amended; CFTC Regulation Part: 23.451; No-Action
12-33