# CFTC Letter No. 22-16: Extension of no-action relief letter 21-24 that was issued to ensure the continued availability, following Brexit of no-action positions under certain existing CFTC comparability determinations and exemption orders or..

> Federal · Agency guidance · Superseded

URL: https://www.frixlaw.com/law-library/statutes/CFTC_L22_16

## Section

- **Citation:** CFTC Letter No. 22-16
- **Heading:** Extension of no-action relief letter 21-24 that was issued to ensure the continued availability, following Brexit of no-action positions under certain existing CFTC comparability determinations and exemption orders or..
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** Superseded
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** CFTC Staff Letters (2008-present) / Extension of no-action relief letter 21-24 that was issued to ensure the continued availability, following Brexit of no-action positions under certain existing CFTC comparability determinations and exemption orders or...

## Text

Summary: Extension of no-action relief letter 21-24 that was issued to ensure the continued availability, following Brexit of no-action positions under certain existing CFTC comparability determinations and exemption orders originally issued by the CFTC for EU entities, while CFTC staff undertakes an analysis of UK law in order to make appropriate recommendations of comparability or exemption to the CFTC.

CFTC LETTER NO. 22-16 NO-ACTION DECEMBER 01, 2022

Re: Extended and Revised No-Action Positions in Connection with Certain
Previously Granted Commission Determinations and Exemptions, in
Response to the Withdrawal of the United Kingdom from the European
Union
I.
Introduction
The Division of Market Oversight (“DMO”) and the Market Participants Division
(“MPD”) (together, the “Divisions”) are jointly issuing this letter to amend the
previously granted no-action positions related to the withdrawal of the United Kingdom
(“UK”) from the European Union (“EU”), known as “Brexit.” In this letter, the Divisions
are extending time-limited no-action positions taken in CFTC Staff Letter 21-241 in
connection with the following actions (collectively, the “Existing Commission
Actions”)
of
the
Commodity
Futures
Trading
Commission
(“CFTC”
or
“Commission”), in response to Brexit:
1.
Comparability Determination for the European Union: Certain Entity-Level
Requirements;2
2.
Comparability Determination for the European Union: Certain Transaction-Level
Requirements;3
1 CFTC Staff Letter 21-24 (November 17, 2021), available at https://www.cftc.gov/csl/21-24/download.
2 Comparability Determination for the European Union: Certain Entity-Level Requirements (December
27, 2013), available at
https://www.cftc.gov/sites/default/files/idc/groups/public/@lrfederalregister/documents/file/2013-
30980a.pdf.
3 Comparability Determination for the European Union: Certain Transaction-Level Requirements
(December 27, 2013), available at
U.S
cftc.gov/csl/21-24/download.
2 Comparability Determination for the European Union: Certain Entity-Level Requirements (December
27, 2013), available at
https://www.cftc.gov/sites/default/files/idc/groups/public/@lrfederalregister/documents/file/2013-
30980a.pdf.
3 Comparability Determination for the European Union: Certain Transaction-Level Requirements
(December 27, 2013), available at
U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5000
www.cftc.gov
Market
Participants
Division
Amanda L. Olear
Director
Division of Market
Oversight
Vincent McGonagle
Director

Page 2

3.
Comparability Determination for the European Union: Margin Requirements for
Uncleared Swaps for Swap Dealers and Major Swap Participants (with items 1
and 2, the “EU Comparability Determinations”);4 and
4.
In the Matter of the Exemption of Multilateral Trading Facilities and Organised
Trading Facilities Authorized Within the European Union from the Requirement
to Register with the Commodity Futures Trading Commission as Swap Execution
Facilities (the “Exemptive Order”).5
Additionally, DMO is amending the terms of the DMO No-Action Positions in CFTC Staff
Letter 21-24 to expand the scope of the no-action positions to an additional multilateral
trading facility (“MTF”) authorized in the UK that is not currently covered by the no-
action positions under CFTC Staff Letter 21-24, but similarly situated to those UK MTFs
and organised trading facilities (“OTFs”) currently covered by CFTC Staff Letter 21-24.
Also, DMO is amending the terms of the DMO No-Action Positions in CFTC Letter 21-24
to remove an MTF and an OTF authorized in the UK from Appendix A to this letter, as a
result of such facilities no longer being in operation
n positions under CFTC Staff Letter 21-24, but similarly situated to those UK MTFs
and organised trading facilities (“OTFs”) currently covered by CFTC Staff Letter 21-24.
Also, DMO is amending the terms of the DMO No-Action Positions in CFTC Letter 21-24
to remove an MTF and an OTF authorized in the UK from Appendix A to this letter, as a
result of such facilities no longer being in operation.
This letter is provided in accordance with the Joint Statement by UK and US Authorities
on Continuity of Derivatives Trading and Clearing Post-Brexit of February 25, 2019.6 It
supersedes CFTC Staff Letter 21-24, and the Divisions’ No-Action Positions taken in this
letter will become effective immediately upon issuance. No person may rely on CFTC
Staff Letter 21-24 after the issuance of this letter.
II.
Background
In June 2016, the people of the UK voted by referendum to leave the EU. On March 29,
2017, the UK submitted notification of its intention to withdraw from the EU at the

https://www.cftc.gov/sites/default/files/idc/groups/public/@lrfederalregister/documents/file/2013-
30981a.pdf.
4 Comparability Determination for the European Union: Margin Requirements for Uncleared Swaps for
Swap Dealers and Major Swap Participants (October 18, 2017), available at
https://www.cftc.gov/sites/default/files/idc/groups/public/@lrfederalregister/documents/file/2017-
22616a.pdf.
5 In the Matter of the Exemption of Multilateral Trading Facilities and Organised Trading Facilities
Authorized Within the European Union from the Requirement to Register with the Commodity Futures
Trading Commission as Swap Execution Facilities (December 8, 2017), available at
https://www.cftc.gov/sites/default/files/idc/groups/public/@requestsandactions/documents/ifdocs/mtf
_otforder12-08-17.pdf
n the Matter of the Exemption of Multilateral Trading Facilities and Organised Trading Facilities
Authorized Within the European Union from the Requirement to Register with the Commodity Futures
Trading Commission as Swap Execution Facilities (December 8, 2017), available at
https://www.cftc.gov/sites/default/files/idc/groups/public/@requestsandactions/documents/ifdocs/mtf
_otforder12-08-17.pdf. See also In the Matter of the Exemption of Multilateral Trading Facilities and
Organised Trading Facilities Authorized Within the European Union from the Requirement to Register
with the Commodity Futures Trading Commission as Swap Execution Facilities: Second Amendment To
Appendix A To Order Of Exemption (July 23, 2020), available at
https://www.cftc.gov/International/ForeignMarketsandProducts/ExemptSEFs.
6 Available at https://www.cftc.gov/PressRoom/PressReleases/7876-19. Pursuant to the Joint Statement,
the Commission committed to extending existing regulatory relief granted by the CFTC to EU firms,
including UK firms, to UK firms at the point of the UK’s withdrawal from the EU.

Page 3

conclusion of a two-year period pursuant to Article 50 of the Treaty on European
Union.7
In January 2020, the UK and the EU finalized the Agreement on the withdrawal of the
United Kingdom of Great Britain and Northern Ireland from the European Union and the
European Atomic Energy Community (the “Withdrawal Agreement”).8 The
Withdrawal Agreement entered into force on February 1, 2020.9 Pursuant to the
Withdrawal Agreement, the UK left the EU as of the end of January 31, 2020 and entered
into a transition period that expired on December 31, 2020
ithdrawal of the
United Kingdom of Great Britain and Northern Ireland from the European Union and the
European Atomic Energy Community (the “Withdrawal Agreement”).8 The
Withdrawal Agreement entered into force on February 1, 2020.9 Pursuant to the
Withdrawal Agreement, the UK left the EU as of the end of January 31, 2020 and entered
into a transition period that expired on December 31, 2020.
To prepare for the expiration of the transition period, the UK government took actions to
provide regulatory certainty, including passing the European Union (Withdrawal) Act
2018 (the “EU(W)A”), which, at the expiration of the transition period, incorporated
relevant EU law and regulations into UK law and regulations, and granted existing
authority vested in certain EU institutions to the Financial Conduct Authority, the Bank
of England including the Prudential Regulation Authority, and Her Majesty’s Treasury.
Commission staff has been engaged with staff of the relevant UK authorities to learn about
the regulatory and supervisory framework that now applies in the UK.
The foregoing actions by the UK government aim to preserve the regulatory status quo
for UK entities benefitting from the Existing Commission Actions in all material respects
following the expiration of the transition period.
In November 2020, ahead of the end of the Brexit transition period, CFTC Staff Letter
20-39 was issued to provide a no-action position benefiting certain swap dealers, as well
as certain MTFs, OTFs, and their market participants. In August 2021, CFTC Staff Letter
21-17 was issued to amend the DMO no-action position provided in CFTC Staff Letter 20-
39 to expand its scope to include three MTFs and one OTF authorized in the UK that were
not eligible to rely on DMO’s no-action position under CFTC Staff Letter 20-39, but were
similarly situated to those UK MTFs and OTFs that were eligible to rely on such position
icipants. In August 2021, CFTC Staff Letter
21-17 was issued to amend the DMO no-action position provided in CFTC Staff Letter 20-
39 to expand its scope to include three MTFs and one OTF authorized in the UK that were
not eligible to rely on DMO’s no-action position under CFTC Staff Letter 20-39, but were
similarly situated to those UK MTFs and OTFs that were eligible to rely on such position.
In November 2021, CFTC Staff Letter 21-24 was issued to extend the time-limited no-
action positions provided in CFTC Staff Letters 20-39 and 21-17.

7 See Article 50 of the Treaty on European Union, available at https://eur-lex.europa.eu/legal-
content/EN/TXT/HTML/?uri=CELEX:12012M050&from=EN.
8 Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the
European Union and the European Atomic Energy Community (Nov. 12, 2019), available at https://eur-
lex.europa.eu/legal-content/EN/TXT/?qid=1580206007232&uri=CELEX%3A12019W/TXT%2802%29.
See also Questions and Answers on the United Kingdom's withdrawal from the European Union on 31
January 2020 (Jan. 24, 2020), available at
https://ec.europa.eu/commission/presscorner/detail/en/qanda_20_104 (stating the President of the
European Council, Charles Michel, and the President of the European Commission, Ursula von der Leyen,
signed and the Prime Minister of the United Kingdom, Boris Johnson, would sign the Withdrawal
Agreement on January 24, 2020).
9 See “The EU-UK Withdrawal Agreement”, available at https://ec.europa.eu/info/strategy/relations-
non-eu-countries/relations-united-kingdom/eu-uk-withdrawal-agreement_en.
ean Council, Charles Michel, and the President of the European Commission, Ursula von der Leyen,
signed and the Prime Minister of the United Kingdom, Boris Johnson, would sign the Withdrawal
Agreement on January 24, 2020).
9 See “The EU-UK Withdrawal Agreement”, available at https://ec.europa.eu/info/strategy/relations-
non-eu-countries/relations-united-kingdom/eu-uk-withdrawal-agreement_en.

Page 4

These CFTC staff letters were meant to maintain the status quo of the Existing
Commission Actions while the Commission worked with the relevant UK authorities to
analyze relevant UK law and, where appropriate, replicate the Existing Commission
Actions for UK entities. The Commission and the relevant UK authorities have not yet
completed this work. Accordingly, the Divisions are further extending the time-limited
no-action positions provided in CFTC Staff Letter 21-24, as described below.
III.
Staff Positions
(A)
MPD No-Action Positions
Pursuant to the EU Comparability Determinations and related Commission rules and
guidance, the Commission has recognized that compliance by certain registered swap
dealers with certain requirements under EU laws and regulations will constitute
compliance with corresponding requirements under certain Commission regulations.
Because the EU laws and regulations relevant for the EU Comparability Determinations
have been incorporated into UK laws and regulations pursuant to the EU(W)A, MPD
believes that temporarily extending the no-action position is warranted
alers with certain requirements under EU laws and regulations will constitute
compliance with corresponding requirements under certain Commission regulations.
Because the EU laws and regulations relevant for the EU Comparability Determinations
have been incorporated into UK laws and regulations pursuant to the EU(W)A, MPD
believes that temporarily extending the no-action position is warranted.
Accordingly, MPD will not recommend that the Commission take enforcement action
against a swap dealer registered with the Commission for failure to comply with
Commission regulation(s) found to be comparable in an EU Comparability Determination
if, in lieu of complying with such Commission regulation(s), it complies with the UK laws
and regulations incorporated pursuant to the EU(W)A in the same manner and subject to
the same conditions contained in the EU Comparability Determinations with respect to
the corresponding EU laws and regulations.
This MPD position will expire upon the earlier of either: (i) the effective date of any
comparability determination issued by the Commission for the UK to the extent such
determination encompasses the subject matter of the EU Comparability Determinations;
or (ii) December 31, 2024.
(B)
DMO No-Action Positions
In the Exemptive Order, the Commission determined that the EU’s regulatory
frameworks for MTFs and OTFs, respectively, satisfy the standard set forth in section
5h(g) of the Commodity Exchange Act (“CEA”)10 for granting an exemption from the
requirement to register with the Commission as a swap execution facility (“SEF”)
pursuant to CEA section 5h(a)(1).11 Based on this determination, the Commission granted

10 CEA section 5h(g) authorizes the Commission to grant an exemption from SEF registration if the
Commission finds that a “swap execution facility … is subject to comparable, comprehensive supervision
and regulation on a consolidated basis by … the appropriate governmental authorities in the home cou
d on this determination, the Commission granted

10 CEA section 5h(g) authorizes the Commission to grant an exemption from SEF registration if the
Commission finds that a “swap execution facility … is subject to comparable, comprehensive supervision
and regulation on a consolidated basis by … the appropriate governmental authorities in the home country
of the facility.” 7 U.S.C. § 7b-3(g).
11 Pursuant to CEA section 5h(a)(1), no person may operate a facility for the trading or processing of swaps
unless the facility is registered by the Commission as a SEF or as a designated contract market. 7 U.S.C. §

Page 5

an exemption from SEF registration to each of the MTFs and OTFs listed in Appendix A
to the Exemptive Order, as such Appendix A may be amended by the Commission from
time to time. Facilities that are granted an exemption from SEF registration pursuant to
CEA section 5h(g) are also eligible facilities upon which counterparties may satisfy the
trade execution requirement of CEA section 2(h)(8).12
Because the EU laws and regulations relevant to the Exemptive Order have been
incorporated into UK laws and regulations pursuant to the EU(W)A, DMO believes that
temporary no-action positions are warranted. Accordingly, DMO will not recommend
that the Commission take an enforcement action against:
(a)
An MTF or OTF that is authorized within the UK and listed in Appendix A to this
letter (each, an “Eligible UK Facility”), for failure to register as a SEF pursuant
to CEA section 5h(a)(1) and Commission Regulation 37.3(a)(1); or
A, DMO believes that
temporary no-action positions are warranted. Accordingly, DMO will not recommend
that the Commission take an enforcement action against:
(a)
An MTF or OTF that is authorized within the UK and listed in Appendix A to this
letter (each, an “Eligible UK Facility”), for failure to register as a SEF pursuant
to CEA section 5h(a)(1) and Commission Regulation 37.3(a)(1); or
(b)
A counterparty that is subject to the trade execution requirement pursuant to
CEA section 2(h)(8), if such counterparty executes a swap that is subject to such
trade execution requirement on an Eligible UK Facility. 13

7b-3(a)(1). CEA section 5h(a)(1) is implemented in the Commission’s regulations through Commission
Regulation 37.3(a)(1). 17 CFR 37.3(a)(1).
12 Facilities that are granted an exemption from SEF registration pursuant to CEA section 5h(g) may also
offer trading in swaps that are not subject to the trade execution requirement to U.S. person counterparties.
13 This no-action position does not affect any other requirements under the CEA or the Commission’s
regulations. In particular, swap transactions executed on Eligible UK Facilities must still comply with:
(1) The reporting requirements of Parts 43 and 45 of the Commission’s regulations which continue to apply
to counterparties that are subject to such reporting requirements;
(2) The swap trading eligibility requirement of CEA section 2(e); and
(3) The following clearing-related requirements:
ations. In particular, swap transactions executed on Eligible UK Facilities must still comply with:
(1) The reporting requirements of Parts 43 and 45 of the Commission’s regulations which continue to apply
to counterparties that are subject to such reporting requirements;
(2) The swap trading eligibility requirement of CEA section 2(e); and
(3) The following clearing-related requirements:
(i)
When a swap transaction executed by a U.S. person on an Eligible UK Facility is a “customer”
position subject to CEA section 4d, the transaction, if intended to be cleared, must be cleared
through a Commission-registered futures commission merchant (“FCM”) at a Commission-
registered derivatives clearing organization (“DCO”);
(ii)
When a swap transaction executed by a U.S. person on an Eligible UK Facility is a “proprietary”
position under Commission Regulation 1.3, the transaction, if intended to be cleared, must be
cleared either through a Commission-registered DCO or a clearing organization that has been
exempted from DCO registration by the Commission pursuant to CEA section 5b(h) (an “Exempt
DCO”); and
(iii)
When a swap transaction is subject to the Commission’s clearing requirement under Part 50 of
the Commission’s regulations, and is entered into by a person that, pursuant to CEA section
2(h)(1), is subject to such clearing requirement, the transaction must be cleared either through a
Commission-registered DCO or an Exempt DCO; provided that, consistent with (i) above, if the
transaction is a “customer” position subject to CEA section 4d, it must be cleared through a
Commission-registered FCM at a Commission-registered DCO, and cannot be cleared through
an Exempt DCO.
If, as a result of the clearing arrangements that an Eligible UK Facility has in place, some swap transactions
executed on the Eligible UK Facility are cleared by a clearing organization that is not a Commission-
a “customer” position subject to CEA section 4d, it must be cleared through a
Commission-registered FCM at a Commission-registered DCO, and cannot be cleared through
an Exempt DCO.
If, as a result of the clearing arrangements that an Eligible UK Facility has in place, some swap transactions
executed on the Eligible UK Facility are cleared by a clearing organization that is not a Commission-

Page 6

The DMO no-action positions taken in this letter will expire upon the earlier of either: (i)
the effective date of any exemptive order issued by the Commission pursuant to CEA
section 5h(g), for MTFs and OTFs authorized within the UK; or (ii) December 31, 2024.
IV.
Conclusion
This letter, and the positions taken herein, represent the views of the Divisions only, and
do not necessarily represent the position or view of the Commission or of any other office
or division of the Commission. The staff positions taken in this letter do not excuse
persons relying on it from compliance with any other applicable requirements contained
in the CEA or in Commission regulations. Further, this letter, and the positions taken
herein, are based upon the facts and circumstances presented to the Divisions. Any
different, changed, or omitted material facts or circumstances might render the staff
positions taken in this letter void.
Finally, as with all staff letters, the Divisions retain the authority to condition further,
modify, suspend, terminate, or otherwise restrict the terms of this letter, and the positions
taken herein, in their discretion.
If you have any questions concerning this correspondence, please contact, Roger Smith,
Associate Chief Counsel, DMO, at (202) 418-5344 or rsmith@cftc.gov; Frank Fisanich,
Chief Counsel, MPD, at (202) 418-5949 or ffisanich@cftc.gov; or Jacob Chachkin,
Associate Chief Counsel, MPD, at (202) 418-5496 or jchachkin@cftc.gov.

Sincerely,

___________________________________
Amanda L
scretion.
If you have any questions concerning this correspondence, please contact, Roger Smith,
Associate Chief Counsel, DMO, at (202) 418-5344 or rsmith@cftc.gov; Frank Fisanich,
Chief Counsel, MPD, at (202) 418-5949 or ffisanich@cftc.gov; or Jacob Chachkin,
Associate Chief Counsel, MPD, at (202) 418-5496 or jchachkin@cftc.gov.

Sincerely,

___________________________________
Amanda L. Olear
Director
Market Participants Division

___________________________________
Vincent McGonagle
Director
Division of Market Oversight

registered DCO, the Eligible UK Facility must, as a condition of receiving the above no-action position from
the SEF registration requirement, have a rule in its rulebook that requires the types of swap transactions
described in clauses (i), (ii) and (iii) above, if intended to be cleared, to be cleared in a manner consistent
with the requirements described in clauses (i), (ii) and (iii), respectively.

Page 7

cc:
Regina Thoele, Compliance
National Futures Association, Chicago
Michael Otten, OTC Derivatives
National Futures Association, New York

Page 8
Appendix A
List of UK Authorized MTFs and OTFs covered by this No-Action Letter
Trading Facility Name
Category
(MTF or OTF)
Home Country
Bloomberg Multilateral
Trading Facility Limited
MTF
United Kingdom
BGC Brokers LP - OTF
OTF
United Kingdom
Creditex Brokerage LLP - MTF
MTF
United Kingdom
Digital Vega MTF
MTF
United Kingdom
Dowgate
MTF
United Kingdom
EBS UK MTF
MTF
United Kingdom
FX Connect - MTF
MTF
United Kingdom
GFI Brokers - MTF
MTF
United Kingdom
GFI Brokers - OTF
OTF
United Kingdom
GFI Securities LTD - MTF
MTF
United Kingdom
GFI Securities LTD - OTF
OTF
United Kingdom
ICAP Securities OTF
OTF
United Kingdom
Integral MTF
MTF
United Kingdom
iSWAP MTF
MTF
United Kingdom
Kyte Broking Limited
OTF
United Kingdom
Refinitiv Transaction Services
Limited
MTF
United Kingdom
TP ICAP UK MTF
MTF
Unite
MTF
MTF
United Kingdom
GFI Brokers - OTF
OTF
United Kingdom
GFI Securities LTD - MTF
MTF
United Kingdom
GFI Securities LTD - OTF
OTF
United Kingdom
ICAP Securities OTF
OTF
United Kingdom
Integral MTF
MTF
United Kingdom
iSWAP MTF
MTF
United Kingdom
Kyte Broking Limited
OTF
United Kingdom
Refinitiv Transaction Services
Limited
MTF
United Kingdom
TP ICAP UK MTF
MTF
United Kingdom
Trad-X
MTF
United Kingdom
Tradeweb Europe Limited MTF
MTF
United Kingdom
Tradition OTF
OTF
United Kingdom
Tradition-NEX OTF
OTF
United Kingdom
Tullett Prebon Europe OTF
OTF
United Kingdom
Tullett Prebon Europe MTF
MTF
United Kingdom

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CFTC_L22_16. Check the current official text before relying on it. Not legal advice.