The Commodity Futures Trading Commission’s Division of Clearing and Risk, Division of Market Oversight, and Market Participants Division issued a no-action letter for certain swap post-trade risk reduction services, covering portfolio rebalancing and basis risk mitigation. The relief responds to a request from Capitolis Partners LLC, Quantile Technologies Limited and TriOptima AB, and states staff will not recommend enforcement action if those providers do not register as swap execution facilities when offering these services. It also extends relief to persons using the services from specified trade execution and clearing submission requirements for the relevant swaps. The letter notes that the three providers are registered with the CFTC as introducing brokers and remain subject to CFTC regulations and National Futures Association rules. It also clarifies that where post-trade risk reduction services fit the description set out in the Commission’s 2020 part 43 final rule, they do not constitute publicly reportable swap transactions and therefore are not subject to part 43 real-time public reporting and dissemination requirements. The no-action relief is time-limited and applies subject to the terms and conditions set out in the letter.
Commodity Futures Trading Commission2026-06-17
Commodity Futures Trading Commission staff issues time limited no action relief for swap post trade risk reduction services
Commodity Futures Trading Commission staff issued a no-action letter for swap post-trade risk reduction services, allowing three providers to operate without registering as swap execution facilities for covered activities. The relief also covers users of portfolio rebalancing and basis risk mitigation services from specified trade execution and clearing submission requirements, and confirms that qualifying services are not subject to part 43 real-time public reporting. The letter is time-limited and subject to conditions.