Key takeaways:

• On December 20, the CFTC issued comparability determinations for a number of “entity-level” business conduct rules for non-US swap dealers and major swap participants in Australia, Canada, the European Union, Hong Kong, Japan and Switzerland. These determinations will permit the covered non-US swap dealers and major swap participants to use compliance with their home jurisdiction as a substitute for compliance with the relevant CFTC regulations.
• The CFTC also issued two no-action letters to allow certain non-US swap dealers and major swap participants to delay their compliance with Parts 45 and 46 reporting requirements with respect to their swaps with certain non-US counterparties and with certain business conduct rules.