On the same day that margin requirements for uncleared swaps kicked in for so-called “Phase I Firms” (September 1), staff of the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission granted “no-action” relief permitting any initial margin posted to or collected from a counterparty by a swap dealer not to have to be posted with an independent third-party custodian as otherwise required by CFTC rule. This relief extends from September 1 through October 3, 2016, only and is subject to various conditions.