The Commodity Futures Trading Commission yesterday issued a no-action letter to allow certain amendments to legacy swaps—those that were executed prior to the compliance date for the CFTC’s uncleared swap margin rule—without losing their status as legacy swaps.
Under the relief provided by the NAL, the following may still be treated as legacy swaps: legacy swaps amended in an immaterial manner; swaps resulting from a swap option that is itself a legacy swap; the remaining portion of a swap following a partial termination of a legacy swap; the remaining portion of a swap following a partial novation of a legacy swap; new swaps resulting from a multilateral compression exercise consisting solely of legacy swaps.
