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December 2016 Housekeeping, Reminders and Updates

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COMMODITY FUTURES TRADING COMMISSION Inter-Affiliate Swaps Transactions No-Action Extension The Commodity Futures Trading Commission (“CFTC”) announced the extension of relief outlined in Letter 15-62 and Letter 16-81 until December 31, 2017. Non-U.S. jurisdictions are still constructing mandatory clearing regimes. The no-action relief extension allows for market participants to more easily satisfy clearing and trade execution requirements while foreign jurisdictions implement these regimes. Additional details regarding the no-action relief extension are available on the Ruddy Gregory, PLLC (“Ruddy Gregory”) website. Risk Disclosure Requirements No-Action Relief Granted In a no-action letter dated November 30, 2016, the CFTC granted the request by futures commission merchants and introducing brokers to combine risk disclosure statements for non-intuitional customers into a single document. The consolidation of the two separate but similar forms formerly required is expected to reduce customer confusion and provide a more efficient process for industry firms. Additional details regarding Regulation 4 rules amendments are available on the Ruddy Gregory website. For further information about any of the topics covered, please feel free to contact Ruddy Gregory, PLLC (www.ruddylaw.com) or 202-797-0762.

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