26-20

Title: 26-20







Description
Provides, subject to certain conditions, no-action positions for post-trade risk reduction service providers for failure to register as a swap execution facility, and for those entering into swaps that are subject to the swap clearing requirement and trade execution requirement.

26-03

Title: 26-03







Description
Joint MPD and DCR interpretative letter addressing the effect of a merger conducted as part of Morgan Stanley’s internal reorganization on the status of certain legacy swaps. Based on the facts and circumstances of the merger as described in the letter, the divisions concluded the swaps at issue retain their legacy swap status under the Commission’s uncleared swap margin and swap clearing requirements.

25-42

Title: 25-42







Description
No-action position on using the definitions of the terms “U.S. person” and “guarantee” in Commission Regulation 23.23 to classify counterparties across the Commission’s cross-border swaps framework and on the continued reliance on the use of prior representations in doing so.

21-28

Title: 21-28







Description

DCR is providing time-limited relief from the swap clearing requirement and related exceptions and exemptions. This relief is to help facilitate the orderly transition from swaps that reference the London Interbank Offered Rate (LIBOR) and other interbank offered rates to swaps that reference alternative benchmarks. (ARRC No-Action Relief Extension Request)

20-43

Title: 20-43







Description

The Divisions do not interpret Sections (2)(h)(1) and 2(h)(8) of the CEA as subjecting to the clearing and trade execution requirements certain swaps transactions entered into by a DCO to reduce and manage the risk associated with a clearing member default.

20-42

Title: 20-42







Description

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

20-25

Title: 20-25







Description

DCR is providing time-limited relief from the swap clearing requirement and related exceptions and exemptions. This relief is to help facilitate the orderly transition from swaps that reference the London Interbank Offered Rate (LIBOR) and other interbank offered rates to swaps that reference alternative benchmarks.

20-22

Title: 20-22







Description

DCR is extending the relief provided by CFTC Letter No. 20-13 and will not recommend that the Commission take enforcement action against the European Stability Mechanism (ESM) for failure to comply with the swap clearing requirement until the earlier of: (i) December 31, 2020, at 11:59 pm (Eastern Time); or (ii) the effective date of final Commission action applicable to swaps entered into by ESM that would otherwise be subject to the Commission’s clearing requirement.

20-13

Title: 20-13







Description

Extended no-action relief for the European Stability Mechanism from the swap clearing requirement in Section 2(h)(1) of the Commodity Exchange Act and Commission regulations 50.2 and 50.4.

13-44

Title: 13-44







Description

No-Action Relief for Eurex Clearing AG with Regard to Sections 5b(a) and 2(h)(1)(A) of the Commodity Exchange Act and Implementing Regulations Thereunder.