On October 31, the SEC issued a statement setting forth its position for a limited time period concerning specific provisions of its Business Conduct Standards for Security-Based Swap (SBS) Dealers and Major Security-Based Swap Participants (Entities). Certain actions with regard to these provisions will not provide a basis for a Commission enforcement action. In addition, the SEC’s position on the ability of parties to security-based swaps to rely on written representations is also addressed by the statement. This statement is intended to minimize potential market disruptions to existing counterparty relationships resulting solely from documentation implementation issues that may arise when security-based swap dealers and major security-based swap participants are required to register with the SEC. Once they are registered with the SEC, entities that are also registered with the Commodity Futures Trading Commission (CFTC) will be required to comply with both the SEC’s Business Conduct Standards as well as analogous rules adopted by the CFTC in 2012 applicable to SBS Entities.