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CFTC Issues No-Action Letter for Swap Risk Reduction Services

The CFTC has issued a no-action letter to certain service providers offering post-trade risk reduction services for swaps, clarifying regulatory expectations and compliance requirements.

The Commodity Futures Trading Commission (CFTC) has announced a no-action letter concerning three service providers—Capitolis Partners LLC, Quantile Technologies Limited, and TriOptima AB—that offer post-trade risk reduction services (PTRRS) for swaps. These services include portfolio rebalancing and basis risk mitigation. The letter states that these providers are not required to register as swap execution facilities if they meet specific criteria, such as registering as introducing brokers and complying with CFTC regulations.

This clarification helps market participants understand that engaging in PTRRS does not automatically trigger certain reporting or registration obligations, provided the services meet the conditions outlined. The no-action letter also emphasizes that these services, if meeting the described criteria, are not considered publicly reportable swap transactions and are exempt from real-time reporting requirements.

The document is time-limited and subject to specific terms and conditions, offering temporary regulatory relief while providing guidance on compliance. This development aims to facilitate risk management in the derivatives market, especially for entities involved in swap transactions and post-trade services.

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