On November 7 2014, the US Commodity Futures Trading Commission  (“CFTC”) Divisions of Clearing and Risk (“DCR”) and Market Oversight (“DMO”) each extended previously-issued no-action relief for certain inter- affiliate transactions. No-action relief that was previously provided in DCR No- Action Letter 14-25 and DMO No-Action Letter 14-26 is being extended until December 31, 2015. Eligible Affiliate Counterparties must satisfy all of the requirements of CFTC regulation 50.52 to be eligible for this relief. Additionally, a counterparty to the swap cannot be located in a non-US jurisdiction for which the CFTC has not determined that a comparable and comprehensive clearing requirement exists. Finally Eligible Affiliate Counterparties opting for this relief must provide, upon request, documentation regarding their compliance with this no-action letter along with regulation 50.52 to the DCR. The CFTC believes that this extension will permit a smooth transition as jurisdictions continue to establish and implement clearing requirements.

The CFTC Staff Letter No. 14-135 proving extension to No-action Letter 14-25 is available at:

http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14-135.pdf

and CFTC Staff Letter No. 14-136 proving extension to No-action Letter 14-26 is available at:

http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14-136.pdf.