The Commodity Futures Trading Commission’s Market Participants Division issued a no-action letter addressing the pre-trade mid-market mark (PTMMM) requirement in Regulation 23.431 for swap dealers and major swap participants. The relief mirrors no-action positions previously provided for certain specified types of swaps, but the letter states it is not limited to those swap types. The CFTC noted it first provided no-action relief in 2012, shortly after the PTMMM compliance date, citing limited informational value and costly operational challenges.
Commodity Futures Trading Commission 2025-04-04
US Commodity Futures Trading Commission issues no-action relief from the pre-trade mid-market mark requirement for swap dealers and major swap participants
The Commodity Futures Trading Commission's Market Participants Division issued a no-action letter regarding the pre-trade mid-market mark requirement in Regulation 23.431 for swap dealers and major swap participants. This relief, not limited to specific swap types, mirrors previous no-action positions due to limited informational value and operational challenges. The CFTC first provided such relief in 2012.