On June 27th, the CFTC's Division of Swap Dealer and Intermediary Oversight issued a time-limited no-action letter relating to requirements imposed on Swap Dealers ("SDs") and Major Swap Participants ("MSPs") pursuant to Commission Regulation 23.504 in connection with (i) foreign exchange transactions that are swaps, and (ii) physically-settled foreign exchange forwards and swap agreements that have been exempted from the definition of swap by the Secretary of the Treasury. The letter provides relief for SDs and MSPs from the requirements of swap trading relationship documentation in accordance with Regulation 23.504 until (1) September 1, 2013 with respect to a counterparty that is an active fund; or (2) December 31, 2013 with respect to any other counterparty except a registered SD or MSP, subject to certain conditions. CFTC Letter No. 13-38.