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On March 31, 2015, the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the “CFTC”) issued no-action relief regarding compliance with certain of its swap regulations, including, but not limited to, business conduct and swap trading relationship documentation requirements for swap dealers (“SDs”), in connection with swaps entered into by structured finance special purpose vehicles (“SPVs”) prior to October 10, 2013 (“Legacy SPV Swaps”). The relief was granted in response to a request by the Structured Finance Industry Group (“SFIG”). Cadwalader represented SFIG in connection with the request.