SIFMA/ISDA/FIA Member Call: CFTC No-Action Letters, FAQs, and Q&As

ISDA MEMBER LOGIN REQUIRED. As the compliance date for a number of the CFTC’s Title VII rulemakings approached on October 12, the Commission released a flurry of No-Action Letters, FAQs and Q&As in an effort to provide much needed relief to market participants. These releases covered a number of rulemaking categories, including guidance on issues relating to which swaps to include in swap dealer and MSP de minimis threshold calculations, cross-border scope, securitizations, FX forwards and swaps, and Commodity Pool and ECP concerns. SIFMA, ISDA and FIA held a Joint Member Call to discuss what relief was provided, whether it goes far enough, and what more can be expected. The Associations, in coordination with counsel from Davis Polk and Mayer Brown, covered: (1) Overview of the CFTC’s Rulemaking & NAL, FAQ, Q&A Process; (2) Cross Border, Registration and Definitional Related Relief; (3) Swap Data Reporting Guidance; (4) FX Forwards and Swaps; (5) Buy-Side Concerns; (6) Clearing; (7) Securitizations.

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