Title: 13-70

CSL Letter Types

CSL Divisions

CSL Issuance Date


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.