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ARTICLE · 01 DECEMBER 2016

CFTC Extends No-Action Relief From Clearing And Trade Execution Requirements For Certain Inter-Affiliate Transactions

Hogan Lovells Cadwalader
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The CFTC Division of Market Oversight ("DMO") and DCR extended previously issued time-limited, no-action relief from clearing and trade execution requirements for certain inter-affiliate transactions.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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The CFTC Division of Market Oversight ("DMO") and Division of Clearing and Risk ("DCR") extended previously issued time-limited, no-action relief from clearing and trade execution requirements for certain inter-affiliate transactions.

CFTC Letter 16-80 extends relief previously granted by CFTC Letter 15-62 and CFTC Letter 14-26 (which had been extended previously by CFTC Letter 14-136) from the trade execution requirement for swaps between affiliates even when the conditions in CFTC Rule 50.52(b)-(d) are not satisfied. The DMO continues to assess the situation involving inter-affiliate swap trading and the trade execution requirement. The DMO continues to consider establishing a permanent exemption, which has been requested by ISDA. The current exemption is now set to expire at 11:59 p.m. EST on December 31, 2017.

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