On February 1, 2023, the Market Participants Division of the CFTC issued a no-action letter with respect to certain external business conduct standards and documentation requirements applicable to swap dealers entering into swaps that are intended to be submitted for clearing contemporaneously with execution. The letter expands upon existing relief by, among other things and subject to certain conditions, applying to all “intended to be cleared” swaps (1) of a type accepted for clearing by a registered or exempt DCO on the date of execution, and (2) that are executed on or pursuant to the rules of a registered or exempt SEF. The revised no-action relief supersedes the prior relief and will expire on December 31, 2025, unless MPD or the CFTC take further action prior to that date.