The Commodity Futures Trading Commission on Thursday issued a no-action letter that provides swap dealers and major swap participants with relief from the requirement to disclose the pre-trade mid-market mark to counterparties in certain foreign exchange transactions involving major currencies.
The disclosure requirements prescribed in Regulation 23.431 state, among other things, that a swap dealer or major swap participant must disclose to certain counterparties the pre-trade mid-market mark of a swap.
The no-action letter issued on Thursday by the CFTC's Division of Swap Dealer and Intermediary Oversight states that a swap dealer or major swap participant need not disclose the pre-trade mid-market mark for a covered forex transaction, provided that: (1) real-time tradeable bid and offer prices for the transaction are available electronically, in the marketplace, to the counterparty; and (2) the counterparty to the transaction agrees in advance, in writing, that the swap dealer
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