Activities

FMLG Correspondence

All documents are in pdf format

The FMLG has submitted the following letters to the CFTC (CFTC response letters are posted where applicable):

• October 2, 2020: The FMLG – Comment Letter on Draft 2020 ISDA Interest Rate Derivatives Definition Provisions Relating to Deliverable Currency Disruption Events and Interest Rate Swaps Referencing Non-Deliverable Currencies

• February 28, 2019: The FMLG - Request for No-Action Relief Regarding Certain External Business Conduct Requirements as they Telate to Off-SEF “Mirror” Transactions in the Prime Brokerage Context

  CFTC No-Action Letter No. 19-06 dated March 22, 2019 Re: No-Action Position for Off-SEF Swaps Executed Pursuant to Prime Brokerage Arrangements

• June 28, 2013: The FMLG – Request for Commission Action with Respect to Reporting of Prime Brokerage Transaction

• June 7, 2013: The FXC and FMLG – Request for Technical Clarification of Relief Granted in CFTC Letter No. 13-12 for Transactions in BIS 31 Currencies

• April 17, 2013: The FXC and FMLG -- Request for
  No-action Relief Regarding Obligation to Provide Pre-Trade Mid-Market Quote (BIS 31 Request)

  CFTC No-Action Letter 13-12 dated May 1, 2013 Re: Relief for Swap Dealers and Major Swap Participants Regarding the Obligation to Provide Certain Disclosures for Certain Transactions Under Regulation 23.431

• April 11, 2013: The FXC and FMLG -- Request for No-action Relief Regarding Obligation to Provide Pre-Trade Mid-Market Quote (Amendment of Condition)

• December 12, 2012: FMLG - Request for No-Action Letter for Swap Dealers in Connection with Foreign Exchange Prime Brokerage, regarding application of the rules relating to reporting of FX Transactions and real-time reporting of FX Transactions

CFTC No-Action Letter No. 12-53 dated December 17, 2012 re: Time-Limited No-Action Relief from (i) Parts 43 and 45 Reporting for Prime Brokerage Transactions, and (ii) Reporting Unique Swaps Identifiers in Related Trades under Partk 45 by Prime Brokers

• December 5, 2012: FMLG - Request for Extension of Compliance Date with External Business Conduct Standards for Swap Dealers in Connection with Foreign Exchange Prime Brokerage

  CFTC No-Action Letter 13-11 dated April 30, 2013 Re: Time Limited Relief for Swap Dealers in Connection with Prime Brokerage Arrangements.

  See also May 6, 2013 ISDA Derivatives/FX PB Business Conduct Allocation Protocol.

  See also May 8, 2013 FXC / FMLG PB Protocol PB Notice to ED Market Practice

• November 28, 2012: FMLG - Request for Extension of the Implementation of the Look-Through Rule and Related Verification and Recordkeeping Requirements

• November 21, 2012: FMLG - Request for Interpretive Letter for Swap Dealers in Connection with Foreign Exchange Prime Brokerage, regarding application of the external business conduct standards

  See December 5, 2012 letter below

• November 21, 2012: FMLG - Request for Interpretive Letter for Swap Dealers in Connection with Foreign Exchange Prime Brokerage, regarding application of the rules relating to reporting of FX Transactions and real-time reporting of FX Transactions

See December 12, 2012 letter below

• November 16, 2012: The FXC and FMLG -- Request for Interpretive Relief Regarding Obligation to Provide Pre-Trade Mid-Market Quote

CFTC No-Action Letter 12-42 dated December 6, 2012 re: Request for Relief Regarding Obligation to Provide Pre-Trade Mid-Market Mark for Certain Foreign Exchange Transaction