EU comparability determinations for entity-level requirements (see Practice Note, The Dodd-Frank Act: Cross-Border Application of Swaps Rules: Substituted Compliance for Entity-Level Requirements).

EU comparability determinations for transaction-level requirements (see Practice Note, see Practice Note, The Dodd-Frank Act: Cross-Border Application of Swaps Rules: Substituted Compliance for Transaction-Level Requirements).

EU comparability determinations for margin requirements for uncleared swaps for swap dealers (SD) and major swap participants (MSP) (see Practice Note, The Dodd-Frank Act: Cross-Border Application of Swaps Rules: CFTC Substituted Compliance Determinations).

Rules requiring UK multilateral trading facilities (MTFs) and organized trading facilities (OTFs) that have comparable requirements to EU MTFs and OTFs to register with the CFTC as swap execution facilities (SEFs) (see Legal Update, CFTC Exempts Four UK Multilateral Trading Facilities (MTFs) From SEF Registration.

The effective date of any comparability determination issued by the CTFC for the UK, so long as the determination encompasses the subject matter of the above-referenced EU comparability determinations.

Six months from the date of the UK's withdrawal from the EU.

The effective date of any technical amendments to the EU comparability determinations.

The expiration of the transition period during with the EU laws and regulations are relevant to the EU comparability determinations continue to apply in the UK.

No-Action Letter 12-70, granting relief to SDs, de minimis dealers (swap dealers that are not registered with the CFTC in any capacity), agent affiliates, and associated persons (APs) from registration as introducing brokers (IBs) under CEA Section 4d, or as commodity trading advisors (CTAs) under Section 4m of the CEA. No-Action Letter 12-70 also clarifies that employees of de minimis dealers are introducing brokers, as defined in Section 1a(31) of the CEA (see Legal Update, CFTC and Bank of England Issue Joint Statement on Post-Brexit Derivatives Trading and Clearing).

No-Action Letter 13-45, granting relief to registered SDs and MSPs from requirements under Part 23 of the CFTC Regulations in connection with uncleared swaps subject to risk mitigation techniques under EMIR (see Legal Update, CFTC and EU Reach Accord on Derivatives Regulation; CFTC Issues Cross-border Guidance and Relief).

No-Action Letter 17-64, granting an extension of time limited relief from the requirements of CFTC Regulations Part 45 and 46 for SDs and MSPs established under the laws of Australia, Canada, the EU, Japan, or Switzerland (see Legal Update, CFTC Issues Fifth Extension of Relief for Certain Non-US Swap Dealers from SDR Reporting Rules).

No-Action Letter 17-66, granting relief for the outward-facing swaps condition (OFSC) in the inter-affiliate exemption from the clearing requirement (see Legal Update, CFTC Issues Fifth Extension of Inter-Affiliate Swap Clearing Exemption).

Letter 17-67, extending relief granted from CEA Section 2(h)(8) for swaps executed between affiliated entities that are not exempt from clearing under CFTC Regulation 50.52 (see Legal Update, CFTC Issues Fifth Extension of Inter-Affiliate Swap Clearing Exemption).

The UK as a country will be extended the same relief as has been extended to the EU.

UK entities will be granted relief in the same manner that relief is granted to EU entities.

UK financial regulatory bodies will be granted relief in the same manner as EU regulatory bodies.

UK laws and regulations that meet all EU operations requirements and which are transposed pursuant to the EU's proposed withdrawal agreement presented to the UK by the EU will be given the same level of relief that is given to the laws of the EU.