On March 14, the CFTC’s Division of Market Oversight issued Letter No. 25-05 to withdraw its Staff Advisory on Swap Execution Facility Registration Requirements, which DMO notes “has created regulatory uncertainty regarding whether certain entities that operate in the swaps market are required to register as SEFs with respect to their particular functions within the swaps market, as well as the specific attributes of their business models.” Firms may consider the following additional points set out in this Client Memorandum in connection with the withdrawal of the Advisory.