2014-02-10 | CFTC Staff Letter 14-12

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CFTC Staff Letter 14-12: No-Action Relief for Package Transactions

The Division grants time-limited no-action relief until 11:59 p.m. Eastern Time on May 15, 2014, to entities or counterparties transacting package transactions from the requirements of Commodity Exchange Act section 2(h)(8). The relief also exempts Swap Execution Facilities and Designated Contract Markets from the requirements of Commission Regulation § 37.9 and Commodity Exchange Act section 5(d)(9) with respect to facilitating trading in such package transactions. A package transaction is defined as a transaction involving two or more instruments executed between two counterparties, priced as one economic transaction with simultaneous execution, containing at least one swap subject to the trade execution requirement, where execution of each component is contingent upon the execution of all others. This relief does not excuse affected persons from compliance with other applicable requirements, including swap reporting, clearing, pre-execution credit checks, and straight-through processing.

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