CPO/CTA Rules & Regulatory Actions CFTC No-Action Letter 15-64: This grants relief for swap transactions between the foreign branch of a U.S. Swap dealer and certain non-U.S. persons RCW Staff - November 20 2015 Share A- A+ 100% Create an account to continue reading Gain instant access to our expert editorial analysis and in-depth insight. Register for free Already have an account? Sign in