The Commodity Futures Trading Commission’s Market Participants Division (MPD) and Division of Clearing and Risk (DCR) issued a no-action letter addressing the application of the CFTC’s swap clearing and uncleared swap margin requirements to certain swaps being transferred from Credit Suisse International to UBS AG London Branch under a UK court-supervised process following the UBS Group AG and Credit Suisse Group AG merger. The relief covers legacy swaps entered into before the relevant CFTC compliance dates and therefore not previously subject to the margin and clearing requirements. Subject to specified conditions, MPD will not recommend enforcement action against certain of UBS AG London Branch’s swap dealer counterparties for failing to comply with uncleared swap margin requirements for the transferred swaps, and DCR will not recommend enforcement action against UBS AG or certain of its counterparties for failing to comply with the swap clearing requirement for those transferred swaps. The letter responds to a request from UBS AG.
Commodity Futures Trading Commission 2025-04-15
Commodity Futures Trading Commission issues no-action relief on swap margin and clearing for Credit Suisse International swaps transferred to UBS AG London Branch
The Commodity Futures Trading Commission's Market Participants Division and Division of Clearing and Risk issued a no-action letter on swap clearing and margin requirements for swaps transferred from Credit Suisse International to UBS AG London Branch after their merger. The relief applies to legacy swaps not previously subject to these requirements, with specified conditions for non-enforcement against UBS AG and its counterparties, responding to a request from UBS AG.