Brexit-related time limited no-action position with respect to certain swap dealer transaction-level requirements

Wells Fargo requests no-action relief permitting the London Branch and its counterparties to comply with the relevant requirements applicable to its Foreign Clients in lieu of the Commissions Transaction-Level Requirements. Wells Fargo requests the no-action relief only with respect to swaps between the London Branch and its Foreign Clients. Based on the foregoing and the representations made by Wells Fargo, the Divisions believe that granting no-action relief is warranted.

Staff interpretation regarding notification of the right to segregation of initial margin in uncleared swap transactions and quarterly reporting under Commission Regulations 23.701 and 23.704