On September 30, 2014, the US Commodity Futures Trading Commission’s (“CFTC”) Divisions of Clearing and Risk and Market Oversight announced the extension of time-limited no-action relief for Swap Execution Facilities (“SEFs”) and Designated Contract Markets (“DCMs”). The extension exempts SEFs and DCMs from compliance with CFTC Regulation 37.9(a)(2) for methods of execution for required transactions, or CFTC Regulations 37.203(a) and 38.152 that prohibit pre-arranged trading, if a SEF or DCM permits a new trade, with terms and conditions identical to the terms and conditions of the original trade (other than the time of execution), to be submitted for clearing. The previous no- action relief will be extended to allow for additional time for market participants to develop the necessary technological solutions to comply with the CFTC regulations. The extended no-action relief will expire on February 16, 2015.

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

http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14-121.pdf.