On December 31st, DSIO announced a no-action position which provides relief, under certain conditions, from the requirement to register as an introducing broker or commodity trading advisor for certain affiliates of a swap dealer or swap counterparty that is within the de minimis exception to the swap dealer definition. The relief also extends to the affiliates' employees where the employees engage in certain activity in support of and on behalf of the swap dealer or swap counterparty. DSIO also announced an interpretive position that an employee of a swap counterparty that is within the de minimis exception to the swap dealer definition who engages in certain activity on behalf of its employer in connection with the employer entering into a swap would not be considered by DSIO to be an IB. CFTC Press Release.