On December 10, 2019, the CFTC reopened the comment period for the proposed capital requirements for swap dealers and major swap participants that are not subject to the capital rules of a prudential regulator.  These rules are the last set of core requirements yet to be finalized for the CFTC’s swap dealer regime.  At the same time, the CFTC separately proposed amendments to the exemption from the CFTC’s swap clearing requirement for swaps between certain affiliated entities that would codify existing no-action relief.  Our client memorandum discusses these proposals in greater detail.


This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.