On November 1, 2016, under No-Action Letter (NAL) 16-76, the CFTC Division of Market Oversight (DMO) extended its time-limited no-action relief for certain swaps executed as part of package transactions from the requirement to trade on a swap execution facility (SEF) (the “trade execution requirement”). DMO extended its relief to November 15, 2017. A tabulated summary of affected package types is available here. This marks the fifth time DMO has delayed compliance from the trade execution requirement for particular types of package trades, highlighting the practical difficulty of implementing the trade execution requirement for certain instruments. (CFTC Commissioner Giancarlo has previously criticized the process of issuing time-limited relief for packaged trades, available here.) Prior no-action letters include NAL 15-55, NAL 14-137, 14-62 and 14-12. Readers interested in puzzles may find it an interesting exercise to read through these letters and parse out how the relief applied at each stage and to what instruments.