Staff is considering recommending the Commission issue a notice of proposed rulemaking (NPRM) to propose certain amendments to the Commission’s business conduct and documentation requirements applicable to swap dealers and major swap participants. The NPRM would codify relief from the pre-trade mid-market mark disclosure requirement and propose exceptions to compliance with certain business conduct and documentation requirements when executing swaps that are: (1) intended by the parties to be cleared contemporaneously with execution; or (2) subject to prime broker arrangements that meet certain qualifying conditions. The proposed amendments, if adopted, would supersede certain no-action positions issued by the Commission’s Market Participants Division. The NPRM may also address outdated record retention requirements.