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Expert Analysis

CFTC's No-Action Relief Fuels Energy Market Competition

By Stuart Armstrong and Barrett Morris ( March 20, 2026, 4:55 PM EDT) -- On Dec. 19, the Market Participants Division of the U.S. Commodity Futures Trading Commission issued CFTC Staff Letter 25-51, providing no-action relief from the obligation to include certain energy commodity end-user swaps in de minimis calculations in determining whether a market participant must register as a swap dealer.[1]...

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