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Commentary by Steven Lofchie

The CFTC Division of Swap Dealer and Intermediary Oversight, the Division of Clearing and Risk, and the Division of Market Oversight (collectively, the "Divisions") extended no-action relief to non-U.S. swap dealers from certain transaction-level requirements under the Commodity Exchange Act. The CFTC stated that in order to avoid market disruptions for their non-U.S. counterparties, non-U.S. swap dealers need sufficient time-limited relief to organize their internal policies and procedures to comply with the transaction-level requirements. Prior to September 30, 2016, or the effective date of

The CFTC has approved, with Commissioner O'Malia dissenting, a series of determinations that would permit "substituted compliance" with the CFTC swaps regulatory regime (i) by dealers located in Australia, Canada, the European Union, Hong Kong, Japan and Switzerland (as to entity-level requirements) and (ii) by dealers located in the European Union and Japan (as to certain transaction-level requirements). "Substituted compliance" describes the circumstances where the CFTC would permit non-U.S. swap dealers to comply with regulations in their home jurisdictions as a substitute for compliance