On March 31, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to provisionally registered swap dealers (SDs) from complying with certain specified regulations when entering into swaps with legacy SPVs. Subject to certain specified conditions, the relief is provided for swaps that are entered into with legacy SPVs in replacement of existing swaps executed on or prior to October 10, 2013, solely for purposes of addressing a reasonably anticipated credit downgrade of an SD counterparty. Press Release. No-Action Relief.