CFTC Staff Provides LIBOR Transition No-Action Relief

In response to requests from the Alternative Reference Rates Committee ("ARRC"), CFTC staff provided relief to market participants relating to the transition from swaps referencing LIBOR and other interbank offered rates (collectively, "IBORs").

The relief covers three general categories: (1) requirements applicable to swap dealers, (2) the trade execution requirement and (3) mandatory clearing.

Swap Dealer Requirements.

In CFTC Letter 19-26, the Division of Swap Dealer and Intermediary Oversight ("DSIO") provided relief relating to IBORs and (1) other interest rates the parties reasonably expect to be discontinued or that have lost relevance as reliable benchmarks and (2) reference rates that succeed any of the foregoing rates. DSIO specifically stated the scope is intended to recognize that swaps could be amended more than once. The relief generally refers to amendments that are in scope under the letter as "qualifying amendments." The relief