View Rule

Since 2014, Commission staff had provided swap execution facilities (SEFs) with a no-action position from Commission Regulation 37.6(b) to allow SEFs to incorporate by reference terms from previously-negotiated agreements between the counterparties into trade confirmations without requiring the SEFs to hold copies of the previously-negotiated agreements. The Commission adopted amendments to the confirmation requirements in order to eliminate the need for a staff no-action position, as formerly set out in staff letter 17-17.