The Commodity Futures Trading Commission’s division of swap dealer and intermediary oversight (DSIO) has issued a no-action letter to provide relief from registration for various swaps intermediaries until 31 December 2012. 

Without the delay, certain entities would have to be registered immediately.
 
Specifically, the letter provides a registration delay for any person who, solely by virtue of its swaps activity, would have been required to register immediately as an introducing broker, commodity pool operator, commodity trading adviser, associated person (AP), floor broker, or floor trader. 

The DSIO letter also provides delay for any person who would be required to register solely because of their involvement with the transition of certain contracts on ICE and NYMEX to clearing as commodity futures and options.
 
Additionally, the letter provides guidance that will permit a swap dealer (SD) or major swap participant (MSP) to employ an AP, notwithstanding that the person is subject to a statutory disqualification, subject to a condition requiring the SD or MSP to consult with the National Futures Association.