No-action letter stating that the Division will not recommend that the Commission commence an enforcement action against a swap execution facility (“SEF”) that does not satisfy the minimum trading functionality requirement set forth in Commission regulation 37.3(a)(2) by offering an order book as defined in Commission regulation 37.3(a)(3) (an “Order Book”), in connection with swap transactions executed on the SEF that are not subject to the trade execution requirement in Commodity Exchange Act (“CEA” or “Act”) section 2(h)(8) (“Permitted Transactions”).