CPO/CTA Rules & Regulatory Actions CFTC No-Action Letter 16-70: Temporary no-action relief regarding custodial arrangements for swap dealers subject to September 1, 2016 compliance date for margin for uncleared swaps RCW Staff - September 1 2016 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