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.