The Commodity Futures Trading Commission issued temporary no-action relief to swap execution facilities  that permit them in connection with a swap transaction (1) to incorporate by reference in mandatory confirmations to the counterparties terms from underlying previously negotiated agreements between the counterparties without such agreements being submitted to a SEF prior to execution and (2) not to receive and maintain the documents incorporated by reference. This relief is conditioned on the CFTC being able to gain access to the relevant agreements and documents upon request within a “reasonable” period and expires at midnight on September 15. (For more details regarding this no-action relief, click here to see the article “CFTC Provides Limited Relief to SEFs from Certain Confirmation and Recordkeeping Requirements” in the August 22 2014 edition of Katten Muchin Rosenman LLP’s Corporate and Financial Weekly Digest.)