DSIO issues no-action transition for March 1, 2017 compliance date for variation margin plus no-action relief from MTA Provisions. The CFTC announced that its DSIO has issued a no-action letter stating that, from March 1, 2017 to September 1, 2017, DSIO will not recommend an enforcement action against a swap dealer (SD) for failing to comply with the variation margin requirements for swaps that are subject to a March 1, 2017 compliance date. DSIO further issued a no-action letter stating that it will not recommend an enforcement action against an SD that does not comply with the minimum transfer amount (MTA) requirements of CFTC Regulations 23.152(b)(3) or 23.153(c) with respect to one or more swaps with any legal entity that is the owner of more than one separately managed account. (2/13/2017) See Q&A - Time-Limited Staff No-Action Letter for Failure to Collect and/or Post Variation Margin under Commission Regulation 23.153. Also see statement of Acting Chairman J. Christopher Giancarlo on no-action relief for March 1, 2017 implementation of variation margin on uncleared swaps.