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.

The Divisions will not recommend that the Commission initiate an enforcement action against Railbird, Bitnomial, or their participants, for failure to comply with Commission regulations 38.8(b), 38.10, 38.951 (only to the extent that regulation 38.951 requires compliance with Part 45 of the CFTC’s regulations), and 39.20(b)(2), as well as the applicable provisions of Parts 43 and 45 of the CFTC’s regulations, or the requirements of the relevant CEA provisions pursuant to which the Relevant Regulations were promulgated, with respect to Railbird Contracts, subject to certain conditions.

Extension of no-action position with respect to Part 45 for entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating consistent with CFTC exemptive orders or no-action positions provided by CFTC staff.

No-action position for swap dealers and major swap participants relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission Regulation 23.431(a)(3)(i).

The Divisions will not recommend that the Commission initiate an enforcement action against Kalshi, Klear, or their participants, for failure to comply with Commission regulations 38.8(b), 38.10, 38.951 (only to the extent that regulation 38.951 requires compliance with Part 45 of the CFTC’s regulations), and 39.20(b)(2), as well as the applicable provisions of Parts 43 and 45 of the CFTC’s regulations, or the requirements of the relevant CEA provisions pursuant to which the Relevant Regulations were promulgated, with respect to Kalshi Contracts, subject to certain conditions.

Supplemental Staff Letter to CFTC Letter15-29 and CFTC Letter 16-72 with respect to swaps trading on certain financial markets that are licensed in Australia and overseen by the Australian Securities & Investments Commission (ASIC).

Extension of no-action position with respect to Part 45 for entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating consistent with CFTC exemptive orders or no-action positions provided by CFTC staff.

Relief under Parts 43 and 45 to entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating under CFTC exemptive orders or no-action relief provided by CFTC staff.

Partial continuation of no-action positions to facilitate physical separation of registrant personnel in response to the COVID-19 pandemic

No-action positions for floor brokers and introducing brokers from oral recordkeeping requirements and designated contract markets from audit trail requirements in continued response to the COVID-19 pandemic