The CFTC’s Division of Market Oversight provided a fourth delay until November 16, 2016, for the application of the Commission’s trade execution requirements in connection with the swap portion(s) of certain so-called “package transactions” that would otherwise be subject to mandatory trading on a designated contract market or a swap execution facility. In approving the delay, Commissioner J, Christopher Giancarlo criticized the proposed requirements, writing that “[a]fter four delays, the CFTC should admit that forcing certain complex package transactions to trade via SEF’s limited execution methods … is simply not workable.” (Click here for additional information on the package transactions impacted by the delay in the article “CFTC Further Extends No-Action Relief for Certain Package Transaction Swaps” in the October 16, 2015 edition of Corporate & Financial Weekly Digest by Katten Muchin Rosenman LLP.)