Staff of the Division of Market Oversight (DMO) of the Commodity Futures Trading Commission (CFTC) are issuing this advisory to remind designated contract markets (DCMs) of the proper procedures for submitting self certifications of an event contract series. The advisory addresses the practice of submitting broad, template style certifications that combine many potential event contract permutations into a single, vague certification.

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).

Revision of CFTC Staff Letter No. 13-70, regarding certain duties imposed on swap dealers (SDs) and major swap participants (MSPs) pursuant to the Commission’s Business Conduct Standards with Counterparties, as well as certain documentation requirements imposed on SDs and MSPs pursuant to Commission regulation § 23.504 for Intended-To-Be-Cleared Swaps.