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    Home /  Insights /  Memos and Newsletters /  Memo
    Memos

    CFTC Staff Issues Pre-Trade Mid-Market Mark Relief

    No-Action Position Relieves Swap Dealers from the Requirement to Provide PTMMMs

    April 7, 2025 | min read |
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    On April 4, 2025, the Market Participants Division (“MPD”) of the CFTC issued CFTC Letter No. 25-09. CFTC Letter No. 25-09 provides that MPD will not recommend that the CFTC commence an enforcement action against a swap dealer or major swap participant (a “Swap Entity”) for failure to provide pre-trade mid-market marks (“PTMMMs”) to its non-Swap Entity counterparties (the “PTMMM Requirement”). The no-action position will remain in effect until the CFTC, following “a reconsideration of the usefulness and effectiveness of the PTMMM Requirements,” adopts revised regulations—the CFTC has not yet proposed any rule changes in this regard. The relief does not affect a Swap Entity’s obligation to provide daily marks or to comply with the CFTC’s transaction reporting requirements.

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