Key takeaways

• The CFTC has further extended its existing no-action relief from the U.S. clearing requirement for swaps between “Eligible Affiliate Counterparties” that comply with certain temporary alternative compliance frameworks with respect to their outward-facing swaps that would otherwise be subject to mandatory clearing. The relief applies through December 31, 2016 (unless the CFTC announces a comparability determination with respect to a particular jurisdiction prior to such date).
• The CFTC has also further extended its existing no-action relief from the trade execution requirement for swaps between Eligible Affiliate Counterparties through December 31, 2016.