On 1 May 2014, the Commodity Futures Trading Commission's ("CFTC") Divisions of Market Oversight ("DMO") and Clearing and Risk ("DCR") announced further implementation of the trade execution requirement for certain interest rate and credit default swaps. Beginning 16 May 2014, market participants executing swaps subject to the trade execution requirement that are part of a so-called "package transaction" must be traded on a Swap Execution Facility ("SEF") or Designated Contract Market ("DCM"), pursuant to a phased compliance timeline. DMO previously provided no-action relief for certain swaps that otherwise were required to be traded on a SEF or DCM to the extent that those swaps were part of a package transaction.

The full text of the CFTC no-action relief is available at: http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14-62.pdf.

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