December 2016 Housekeeping, Reminders and Updates

COMMODITY FUTURES TRADING COMMISSION Inter-Affiliate Swaps Transactions No-Action Extension The Commodity Futures Trading Commission (“CFTC”) announced the extension of relief outlined in Letter 15-62 and Letter 16-81 until December 31, 2017. Non-U.S. jurisdictions are still constructing mandatory clearing regimes. The no-action relief extension allows for market participants to more easily satisfy clearing and trade execution requirements while foreign jurisdictions implement these regimes. Additional details regarding the no-action relief extension are available on the Ruddy Gregory, PLLC (“Ruddy Gregory”) website. Risk Disclosure Requirements No-Action Relief Granted In a no-action letter dated November 30, 2016, the CFTC granted the request by futures…

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