April 04, 2025

WASHINGTON, D.C. — The Commodity Futures Trading Commission’s Market Participants Division today issued a no-action letter in relation to the Pre-Trade Mid-Market Mark (PTMMM) requirement in Regulation 23.431 for swap dealers and major swap participants.   

The CFTC first issued a no-action letter regarding the PTMMM requirement in 2012, shortly after the PTMMM compliance date, because it did not provide significant informational value and created costly operational challenges. Today’s no-action letter provides a similar no-action position as those in certain prior no-action letters for certain specified types of swaps, as described in the letter, but is not limited to such types of swaps. 

-CFTC-