Letters

Project KISS Initiative in Regards to Extension of Certain Time-Limited No-Action Relief

Summary

SIFMA, IIB and ISDA submitted comments in response to the CFTC’s Project KISS initiative (RIN 3038-AE55) covering the extension of certain time-limited no-action relief. The associations and their members appreciate the Commission and staff’s continued attention to no-action relief to address difficulties presented by rules. Some have needed to be extended several times to address unresolved issues and the cycle of requesting, discussing and granting extensions of relief, however, results in unnecessary uncertainty and resource consumption for both market participants and Commission staff. Extending such relief until the effective date of related, needed changes in regulation will have a positive impact, providing certainty for market participants and the Commission, alike. The submission includes an appendix that identifies specific no-action letters we believe would benefit from such an approach.

See also:
CFTC Requests Public Input on Simplifying Rules

PDF

Submitted To

CFTC

Submitted By

SIFMA, IIB and ISDA

Committee

Derivatives Division

Date

24

July

2017