On September 29, 2014, the US Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight announced an extension of no-action relief previously granted on December 31, 2013, providing time-limited relief relating to certain occasional, off-facility, cleared credit default swaps (“CDS”) entered into pursuant to a derivative clearing organization’s rules related to its price submission process for determining end-of-day settlement prices for cleared CDSs (“CDS Settlement Price Process”). Under the no-action letter, the CFTC will not commence an enforcement action against any clearing member of a derivative clearing organization for entering into a swap through the CDS Settlement Price Process and not through a swap execution facility or a designated contract market. In addition, counterparties for such swaps will be relieved of their obligation to report swap data under the CFTC no-action letter. The extension of the no-action relief will expire on September 30, 2015.

The full text of the CFTC no-action letter is available at: http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14- 119.pdf.