Key takeaways

• The Division of Clearing and Risk of the CFTC has issued a time-limited no-action letter extending for another year its existing no-action relief from the “Outward-Facing Swaps Condition” of the “Inter-Affiliate Exemption” from clearing, thereby allowing “Eligible Affiliate Counterparties” to continue to comply with certain temporary alternative compliance frameworks in lieu of complying with the Outward-Facing Swaps Condition.
• The Division of Market Oversight of the CFTC has issued a time-limited no-action letter extending for another year its existing no-action relief from the “trade execution requirement” for swaps between Eligible Affiliate Counterparties.
• The relief in both letters expires on December 31, 2015.