CFTC Issues a ‘No Action’ Letter that Exempts FX Prime Brokers from Certain Aspects of Dodd-Frank

The Commodity Futures Trading Commission (CFTC) has issued a time limited ‘No Action’ letter that exempts Prime Brokers from certain aspects of Dodd-Frank rules. There had been widespread concern that Prime Brokers would be required to comply with the obligation to disclosure of the mid-market mark. The CFTC No Action letter recognized that the prime broker would…