News & Analysis as of

Commodity Exchange Act (CEA) Dodd-Frank Wall Street Reform and Consumer Protection Act No-Action Letters

Eversheds Sutherland (US) LLP

CFTC issues no-action letter regarding CME’s listing of event contracts

On July 22, 2025, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk issued a no-action letter (CFTC Letter No. 25-23) granting targeted regulatory relief to the...more

Mayer Brown

Everyone’s Human: CFTC Rationalizes Swap Error Reporting

Mayer Brown on

On July 31, 2025, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for certain swap reporting counterparties that fail to submit a swap data error correction notification (“NAL 25-25”). This relief...more

Morgan Lewis

CFTC Releases No-Action Letter 14-144

Morgan Lewis on

The letter modifies previous No-Action Letter 13-22, to expand relief for treasury affiliates entering into swaps on behalf of non-financial end-user affiliates that could otherwise elect the exception in section 2(h)(7) of...more

Orrick - Finance 20/20

CFTC Provides Relief from the Clearing Requirement for Swaps Entered into by Eligible Treasury Affiliates

Orrick - Finance 20/20 on

On November 26, CFTC issued a no-action letter providing additional relief for eligible treasury affiliates that enter into swaps that are subject to the clearing requirement in section 2(h)(1) of the Commodity Exchange Act...more

Latham & Watkins LLP

CFTC Hosts End-User Roundtable

Latham & Watkins LLP on

The Commission responds to issues facing end-users as a result of derivatives reforms. Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended the Commodity Exchange Act...more

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