Many types of credit default swaps (CDS) and interest rate swaps (IRS) are currently subject to mandatory clearing and mandatory execution on a swap execution facility (SEF) or a designated contract market (DCM). Execution of package transactions,[1] however, has presented implementation challenges. As a result, the Commodity Futures Trading Commission (CFTC) previously granted no-action relief postponing the date execution of package transactions on SEFs and DCMs would be required.[2]

The previous no-action relief has expired for some types of package transactions, and the trade execution mandate must be met for those transactions. For other types of package transactions, the CFTC issued a no-action letter on November 10, 2014, affording market participants additional time to comply with the trade execution mandate, as summarized in the compliance timeline below.[3] For parties to these package transactions, the CFTC is providing additional time to execute package transactions on SEFs or DCMs. For SEFs and DCMs, the CFTC is providing additional time to comply with requirements related to trade execution processes.

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