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March 15, 2017

CFTC Issues Time-Limited No-Action Transition Compliance Date for Variation Margin and No-Action Relief

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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.

View full memo, CFTC Issues Time-Limited No-Action Transition Compliance Date for Variation Margin and No-Action Relief

Authors and Contributors

Donna Parisi

Partner

Derivatives & Structured Products

+1 212 848 7367

+1 212 848 7367

New York

Geoffrey Goldman

Partner

Derivatives & Structured Products

+1 212 848 4867

+1 212 848 4867

New York

Azam Aziz

Partner

Derivatives & Structured Products

+1 212 848 8154

+1 212 848 8154

New York