The Commodity Futures Trading Commission granted relief until December 15, 2015, from certain regulatory obligations in connection with block trades related to swap transactions executed on or subject to the rules of swap execution facilities. Under CFTC rule, future commission merchants that are members of derivatives clearing organizations must have risk-based limits and screen all orders for compliance with those limits before execution. Swap execution facilities must also coordinate with each DCO to which it submits transactions for clearing procedures to ensure straight-through processing. The CFTC has said these requirements together mean that “a SEF must facilitate pre-execution screening by each Clearing FCM on an order-by-order basis.” Acknowledging limitations in technology, the CFTC is temporarily granting relief from these requirements in connection with block trades of swaps that are listed on a SEF and subject to the SEF’s rules, that are privately negotiated and are not executed on the SEF’s order book functionality, and subject to various conditions.