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On February 13, 2017, the US Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued a time-limited no-action letter (CFTC Letter 17-11) which provides that, from March 1, 2017 to September 1, 2017, the DSIO will not recommend an enforcement action against a swap dealer for failure to comply with the variation margin requirements for swaps that are subject to a March 1, 2017 compliance date.