On Aug. 31, 2020, the Commodity Futures Trading Commission announced that three of its divisions have respectively issued revised no-action letters providing additional relief to swap dealers and market participants related to the industry-wide initiative to transition from swaps that reference LIBOR and other interbank offered rates to swaps referencing alternative benchmarks.
The Division of Swap Dealer and Intermediary Oversight issued “CFTC Staff Letter No. 20-23” to provide relief to swap dealers from registration de minimis requirements, uncleared swap margin rules, business conduct requirements, confirmation, documentation and reconciliation requirements and certain other eligibility requirements.
The Division of Market Oversight issued “CFTC Staff Letter No. 20-24” to provide time-limited relief from the trade execution requirement.
The Division of Clearing and Risk issued “CFTC Staff Letter No. 20-25” to provide time-limited relief from the swap clearing requirement and related exceptions and exemptions.