The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) recently announced that it is providing no-action relief, subject to specified conditions, to registered swap dealers from compliance with the variation margin requirements of CFTC regulation 23.153 when amending or novating swaps in existence prior to March 1, 2017 with issuers that are special purpose vehicles (legacy SPV swaps).
DSIO previously provided similar relief from certain business conduct standards concerning the legacy SPV swaps in a 2015 no-action letter (CFTC Staff Letter 15-21).
