CFTC Eliminates PTMMM Disclosure Requirements for Swap Entities
By EsqSocial Corporation 17/04/25
On April 4, 2025, the CFTC's Division of Market Participants issued No-Action Letter 25-09 regarding the controversial Pre-Trade Mid-Market Mark ("PTMMM") requirements in CFTC Regulation 23.431, effectively eliminating the PTMMM disclosure requirements for swap dealers and major swap participants (collectively, "swap entities"). This is particularly notable because since the PTMMM disclosure requirements were initially adopted in 2012, the CFTC brought and settled 12 enforcement actions against...
By: Davis Wright Tremaine LLP