Key takeaways

• The Division of Market Oversight of the CFTC has issued a no-action letter extending and expanding its existing no-action relief (1) from the trade execution requirement for swap counterparties and (2) from certain requirements relating to the method of execution and the offering of an Order Book for swap execution facilities and designated contract markets, each with respect to certain interest rate and credit default swaps that have been made available to trade and are executed as part of certain specified categories of package transactions.
• The no-action letter covers three categories of package transactions that were already subject to the prior no-action relief, as well as three additional categories.
• The length and scope of the no-action relief provided varies by category of package transaction.