The CFTC proposal to implement an alternative compliance framework for the inter-affiliate swaps clearing exemption was published in the Federal Register. Comments on the proposal must be submitted by February 21, 2020.

As previously covered, the CFTC unanimously approved a proposal that would implement an alternative compliance framework for the inter-affiliate swaps clearing exemption. According to the CFTC, the proposal would amend CFTC Rule 50.52 to "reinstate the expired alternative compliance frameworks for the inter-affiliate swaps clearing exemption, with minor revisions to reflect the current variation margining practices of affiliated counterparties electing the exemption." The CFTC indicated that the proposal would (i) codify staff no-action letters providing exceptions and (ii) offer the two alternative compliance frameworks to associated entities permanently.