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February 14, 2017

Stroock Special Bulletin

Yesterday the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued a time-limited no-action letter stating that from March 1, 2017, to September 1, 2017, DSIO will not recommend an enforcement action against a swap dealer (“SD”) for failure to comply with the variation margin (“VM”) requirements for swaps that are subject to a March 1, 2017 compliance date. 

This Stroock Special Bulletin provides a brief overview of the no-action letter.