The letter modifies previous No-Action Letter 13-22, to
expand relief for treasury affiliates entering into swaps on behalf
of non-financial end-user affiliates that could otherwise elect the
exception in section 2(h)(7) of the CEA and section 50.50 of the
Commission's regulations.
On November 26, the U.S. Commodity Futures Trading
Commission's (CFTC's) Division of Clearing and Risk
(Division) issued No-Action Letter 14-144.1 The letter
provides further relief for eligible treasury affiliates that enter
into swaps that are subject to a mandatory clearing requirement
under section 2(h)(1) of the Commodity Exchange Act (CEA) and part
50 of the CFTC's regulations. In seeking to address
"certain challenges faced by treasury affiliates in
undertaking hedging activities on behalf of non-financial
affiliates within a corporate group," the new no-action letter
expands prior relief granted under No-Action Letter 13-22, issued
on June 4, 2013.
