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Since 2014, Commission staff has 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 has proposed amendments to the confirmation requirements in order to eliminate the need for a staff no-action position, as currently set out in staff letter 17-17.