CFTC Staff Letters Archive

CFTC Staff Letters Archive provides Letters from 2007 and earlier. For Letters published 2008 or later visit the All Letters page.

There are no Advisory Letters or Other Written Communications for 2007 or earlier.

Date	PDF and Description
02/03/1993	93-08 ; Regulation 4.7;; No-Action The Division of Trading and Markets permitted a CPO to claim relief under Regulation 4.7, where the three non-QEPs in its pool were directors of the CPO, listed as principals of the CPO, and accredited investors with significant financial industry backgrounds. (T&M)
01/25/1993	93-07 ; Regulation 1.46;; No-Action The Division of Trading and Markets relieved an FCM from compliance with the close-out and offsetting requirements of Regulation 1.46, where the customer had four accounts at the FCM which were to be managed by an IB?s AP. (T&M)
12/21/1992	93-03 ; Regulation 4.12(b);; No-Action The Division of Trading and Markets permitted certain CPOs who were operating their pool in full compliance with Part 4 to subsequently operate the pool pursuant to Regulation 4.12(b), provided they amended the pool?s Disclosure Document to bring it into conformity with the ten percent trading limitation of Regulation 4.12(b). (T&M)
12/10/1992	93-02 ; Regulation 4.7;; No-Action The Division of Trading and Markets permitted a CPO to claim relief under Regulation 4.7, where the non-QEP in the pool was an accredited investor who had been employed by the CPO for 16 years. (T&M)
12/10/1992	93-01 ; Regulation 4.7;; No-Action The Division of Trading and Markets permitted a CPO to claim relief under Regulation 4.7, where the non-QEPs in the pool would continue to receive the full Part 4 disclosures and reporting. (T&M)
11/06/1992	92-20 ; Section 4m(1);; No-Action The Division of Trading and Markets granted CPO and CTA registration no-action relief to an FCM and agricultural cooperative in connection with administering a program of joint commodity interest trading accounts. (T&M)
10/09/1992	92-19 ; Section 4d;; No-Action The Division of Trading and Markets granted IB registration no-action relief to a foreign bank which had branches in the U.S., where certain conditions were met. (T&M)
09/23/1992	92-16 ; Regulations 1.33, 1.37 and 1.55;; No-Action The Division of Trading and Markets permitted an FCM and its foreign broker affiliate to have their institutional customers transmit trading orders directly to their respective overseas foreign broker. (T&M)
09/02/1992	92-14 ; Section 4a(1) and Regulations 150.2 and 150.3;; No-Action The Division of Economic Analysis granted no-action relief to J. Aron & Company with respect to speculative position limits relating to spread or arbitrage trading of Goldman Sachs Commodity Index futures or options contracts and the underlying futures contracts or options on such futures contracts if the following conditions are met: (1) the spread or arbitrage positions are as a totality offsetting; (2) the positions in the underlying contracts are not in the spot month; and (3) the positions in any individual month or in all months combined do not exceed the all months combined limit specified in Reg. ?150.2.
06/25/1992	92-11 ; Section 4d;; No-Action The Division of Trading and Markets permitted certain U.S. exchange members to solicit, accept and enter U.S. customer orders into the Globex system through designated persons located at foreign affiliates not registered as an FCM.