On March 20th, the CFTC's Division of Clearing and Risk issued a no-action letter that provides relief from required clearing for a limited set of "stub swaps" that remain after the partial novation or partial termination of an original swap that was not required to be cleared because it was executed prior to an applicable compliance date for required clearing. The Division will not recommend enforcement action against any person for failing to clear stub swaps resulting from partial novations or partial terminations, provided that the original swaps were executed prior to the date on which the counterparties must begin complying with the clearing requirement. Both the original swaps and stub swaps, and the related partial novations and terminations, must meet certain conditions specified in the letter. CFTC Press Release.