On September 19, 2014, the US Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued time-limited no-action relief for Swap Execution Facilities (“SEFs”) from certain block trade requirements. The CFTC no-action relief specifically exempts SEFs from the “occurs away” requirement under CFTC Regulation 43.2 and allows SEFs to facilitate the execution of block trades on non-Order Book trading systems or platforms subject to certain conditions outlined in the no-action letter. The time-limited no-action relief granted by the CFTC will end on December 15, 2015.

The full text of the CFTC no-action letter is available at:

http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14-118.pdf.