CFTC Issues No-Action Relief to Swap Dealers from Obligation to Provide Pre-Trade Mid-Market Mark (PTMMM)


The CFTC’s Market Participants Division (MPD) issued No-Action Letter 25-09, providing relief from the obligation of swap dealers to provide their non-dealer swap counterparties with a pre-trade mid-market mark (PTMMM) for the transaction, as required by CFTC Regulation 23.431. Industry groups requested the relief after many years of market pushback on the requirement.

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