DMO is extending a time-limited no-action position with respect to the compliance date for the November 25, 2020 amendments to certain rules pertaining to block thresholds and cap sizes in Part 43.
Request Letter No. 2
Request Letter No. 3

Letter 13-48 grants relief from grants relief from the aggregation prohibition in § 43.6(h)(6) for certain commodity trading advisors (“CTAs”) and investment advisors (“IAs”) with respect to large notional off-facility swaps. The no-action letter provides that until October 1, 2013 at 11:59 pm EST, the Division will not recommend that the Commission take enforcement action against CTAs and IAs that aggregate orders for the purpose of executing large notional off-facility swaps, provided they meet specified conditions.