The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) today issued a no-action letter that provides relief for persons engaging in multilateral portfolio compression exercises.
The Division will not recommend that the Commission take enforcement action against any person for failure to include in its calculation of the aggregate gross notional amount of swaps connected with its swap dealing activity for purposes of Commission Regulation 1.3(ggg)(4), terminations of swaps (in whole or in part) or swaps entered into as replacement swaps as part of a multilateral portfolio compression exercise (as defined in Commission Regulation 23.500). The relief provided is not time limited.