On January 8, the Commodity Futures Trading Commission Division of Market Oversight issued a no-action letter (the Letter) supplementing the relief provided in CFTC Letter 17-27. CFTC Letter 17-27 generally permitted swap execution facilities (SEFs) and designated contract markets (DCMs) to correct clerical or operational errors discovered after a swap has been cleared.

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On December 18, the Division of Swap Dealer and Intermediary Oversight (DSIO), the Division of Market Oversight (DMO) and the Division of Clearing and Risk (DCR) each issued a no-action letter providing relief to market participants in preparation for the transition away from the London Interbank Offered Rate (LIBOR) and other interbank offered rates (collectively with LIBOR, IBORs). The letters identify the terms and conditions pursuant to which counterparties may be eligible for relief in connection with amending swaps to replace provisions referencing discontinued IBORs with alternative benchmarks.
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On December 18, National Futures Association (NFA) announced that its recent amendments to NFA Compliance Rule 2-34 and two interpretive notices relating to performance reporting and disclosures by commodity pool operators and commodity trading advisors will take effect on February 1, 2020.

More information about the amendments is available in the September 6 edition of

On December 3, the National Futures Association (NFA) proposed amendments to various NFA Compliance Rules and Interpretive Notices related to discretionary customer accounts, customer information, risk disclosures and bunched orders to apply to cleared swaps, in addition to other minor amendments. Most notably, NFA proposal would amend the following:
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On December 4, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) issued an advisory addressing the preparation of the Chief Compliance Officer (CCO) Annual Report for futures commission merchants, swap dealers and major swap participants. The CFTC advisory discusses a number of common deficiencies that the staff has identified in its review of the 2019 CCO Annual Reports and provides additional guidance to Registrants regarding the requirements of the CCO Annual Report in light of the deficiencies found.
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