On November 29th, the CFTC's Division of Swap Dealer and Intermediary Oversight issued a no-action letter stating that DSIO will not recommend that the Commission take an enforcement action against any swap dealer or covered associate of any SD for failure to be fully compliant with Regulation 23.451 with respect to "governmental plans" as defined in Section 3 of ERISA. The relief effectively means that the agency will not enforce "pay-to-play" prohibitions against banks selling swaps to pensions. The letter also clarifies the scope of the two-year "look-back" period in Regulation 23.451. DSIO believes that the "look-back" period does not include any time period that precedes the date on which an SD is required to register as such. CFTC Press Release.