No-action position for intended-to-be-cleared swaps traded on Eligible UK Trading Venues (as defined in the letter).

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.

No-action position for registered swap dealers and major swap participants that enter into certain swaps referencing the Secured Overnight Financing Rate (described in the letter) relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission regulation 23.431(a)(3)(i).

No-Action Position for Off-SEF Swaps Executed Pursuant to Prime Brokerage Arrangements