The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight again delayed the application of transaction level requirements by non-US swap dealers who engage in swaps with other non-US persons when the swaps are regularly arranged and facilitated by employees or agents located in the United States. The CFTC previously has taken the view that such activities conducted within the US by such persons would cause the non-US swap dealer to have to apply certain transaction level requirements. (Transaction level requirements generally address mandatory clearing and swap processing, margining and segregation for uncleared swaps, mandatory trade execution, swap trading relationship documentation, real-time reporting; trade confirmation; daily trading records, and external business conduct standards, among other matters.) Staff’s latest relief expires on September 29, 2015. (Click here to see information regarding the original CFTC staff advisory in the article “CFTC Issues Advisory Related to the Arrangement of Swaps Involving Non-US Swap Dealers by US Persons” in the November 11 to 15 and 18, 2013 edition of Bridging the Week.) Separately, the CFTC’s Division of Market Oversight provided a further delay to the application of the Commission’s trade execution requirements in connection with the swap portion(s) of so-called "package transactions" that would otherwise be subject to mandatory trading on a designated contract market or a swap execution facility. The new relief has various expiration dates for six different types of package transactions and the methodology of execution on a SEF or DCM, ranging from May 15, 2015, to February 12, 2016.