CFTC No-Action Letter (13-39) Providing Relief for Swap Dealers in Connection with FX Prime Brokerage (with Lofchie Comment)

Division of Swap Dealer and Intermediary Oversight ("DSIO") today issued a time-limited no-action letter that provides swap dealers with relief from certain External Business Conduct Standards rules in the context of foreign exchange intermediated prime brokerage arrangements. The relief provided in the no-action letter is applicable to all swap dealers, subject to the conditions and limitations set forth in the letter.

Lofchie Comment: Another no-action letter subject to numerous conditions and requiring yet more documentation.

Click here to view the No-Action Letter.