CFTC Revises LIBOR Transition No-Action Letters

The CFTC issued revised no-action letters regarding the financial industry's transition away from LIBOR.

The Division of Clearing and Risk, Division of Market Oversight, and the Market Participants Division of the CFTC released revised no-action letters that the CFTC indicated were intended to address the current expected cessation dates of various LIBORs (in particular, that USD LIBOR will be provided through June 30, 2023).

The series of revised no-action letters are in reference to the date confirmation regarding 2023 USD LIBOR settings. The following revisions and extensions were made:

• Letter No. 21-26revises Letter No. 20-23, addressing various requirements applicable to swap dealers and de minimis dealers, including business conduct, documentation, and de minimis counting;