The US Commodity futures Trading Commission (CFTC) has extended the no-action relief for non-US swap dealers that enter into swaps with non-US persons to 15 September 2014. This is following the CFTC receiving multiple requests from such entities for no-action
relief on the basis that failure to do so would result in market disruption for their non-US counterparties and that time was needed to allow internal policies and procedures to be implemented to meet the transaction level requirements.
The Divisions of the CFTC have now stated that they will not recommend that the Commission take any enforcement action against any non-US swap dealer (whether or not an affiliate of a US person) for failure to comply with any transaction level requirements
with respect to any covered transaction.
In November 2013 the CFTC requested public comment on the terms of these requirements. The deadline for feedback is 10 March 2014.