Key takeaways:

• The CFTC has issued a no-action letter expanding the no-action relief from the IB and CTA registration requirements previously granted under CFTC Letter No. 12-70 to certain additional persons that engage in Affiliate Support Activities on behalf of certain affiliates not yet registered with the CFTC as an SD.
• The relief applies where the employee of an Agent Affiliate engages in such activities on behalf of an affiliate swap counterparty that either has filed a Form 7-R or has engaged in more than a de minimis amount of swap dealing but has not submitted a complete application for registration and less than two months have elapsed since the end of the month in which it exceeded such de minimis amount.
• The relief is subject to a number of conditions and expires once the affiliate swap counterparty registers as an SD.