DSIO not recommending enforcement against swap dealer that is a dual SD/JFSA. The International Swaps and Derivatives Association (Japan) requested a no-action position on behalf of its members who are swap dealers that are subject to the uncleared swap margin requirements of both the CFTC and the Financial Services Agency of Japan (JFSA) from the CFTC’s requirement under CFTC Regulation 23.153 to post and collect variation margin from certain financial counterparties within one business day of the execution of an uncleared swap and on a daily basis after that. On February 23rd, the CFTC’s Division of Swap Dealer and Intermediary Oversight stated that it will not recommend an enforcement action against an SD that is a dual SD/JFSA covered entity for failure to comply with the CFTC’s variation margin posting and collection timing requirements, subject to certain conditions. (2/23/2017)