November 12, 2014
"Many times when a regulator issues a no-action letter, the relief granted is industry-wide. This is not a case like that. But, of course, any firm that has a similar fact situation will want similar relief, and I expect the firm would be able to get the same treatment. And then at some point, if enough firms request the relief, the CFTC, as a commission, would likely propose a broader market-wide exemption or rule amendment."
- Steven Lofchie comments in Risk.net on a no-action letter issued by the U.S. Commodity Futures Trading Commission (CFTC) to Southwest Airlines on November 6 that may herald a broader shift in the CFTC's policy of requiring commodity derivatives end-users to report their swap trades in real time.