Request for No-Action Relief: Recordkeeping Requirements under the Internal Business Conduct Rules

Published on:
August 10, 2012
Submitted to:
CFTC
Submitted by:
SIFMA

SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) requesting no-action relief for recordkeeping requirements under the Internal Business Conduct Rules, 77 Federal Register 20128; April 3, 2012; Final Rule (CFTC: RIN 3038-AC96).  SIFMA requests that the Division of Swap Dealer and Intermediary Oversight (Division) of the CFTC confirms it will not recommend that the CFTC take enforcement action against a firm not in compliance with certain other requirements of Subpart F described as of the compliance date and for a period of time thereafter.

The CFTC issued a Final No-Action Letter on October 26, 2012.

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