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 |
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91-07  ; Section 4m(1);; No-Action The Division of Trading and Markets granted CTA registration no-action relief to a registered investment adviser providing commodity interest trading advice to a foreign subsidiary in a manner solely incidental to its business of providing securities advice. (T&M) |
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| 91-06 ; Section 4m(1);; No-Action The Division of Trading and Markets granted CPO registration no-action relief to two natural person general partners of a commodity pool, where two corporate general partners were registered as CPOs and the natural persons were registered as APs of one of those CPO registrants. (T&M) |
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| 91-1 OETF ; Sections 4(a) and 4c and Regulations Part 4;; No-Action The Off-Exchange Task Force granted no-action relief to GaiaCorp U.S. Limited based upon GaiaCorp's privately offered "Institutional Investors Only" Fund (made up solely of institutional investors) which will trade in off-exchange transactions for the future delivery of foreign currencies as well as off-exchange foreign currency option contracts. |
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| 91-05 ; Regulation 4.5;; No-Action The Division of Trading and Markets granted CPO registration no-action relief to the Board of Trustees of an employee welfare benefit plan, where the plan’s assets would be invested in commodity interests for hedging purposes. (T&M) |
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| 91-04 ; Section 4m(1);; No-Action The Division of Trading and Markets granted CPO registration no-action relief to the U.S. directors of an offshore fund, where all the directors were registered as APs. The Division also provided CTA registration relief under these circumstances. (T&M) |
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| 91-03 ; Section 4e;; No-Action The Division of Trading and Markets permitted an employee of a partnership to trade commodity interests for the partnership’s proprietary account without registering as a CTA, pending effectiveness of the employee’s floor broker registration. (T&M) |
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| 91-01 ; Regulation 4.31;; No-Action The Division of Trading and Markets permitted a CTA which was 90% owned by a second CTA but which operated independently and used its own trading system to not disclose the past performance of the second CTA in its Disclosure Document. (T&M) |
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| 90-18 ; Regulation 4.21;; No-Action The Division of Trading and Markets permitted a CPO to accept additional subscriptions to its pool from the pool’s sole limited partner without first having to deliver a Disclosure Document. (T&M) |
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| 90-4 DEA ; Section 4a(1) and Regulations 150.2 and 150.3;; No-Action The Division of Economic Analysis granted no-action relief to Mint Investment Management Company and Northfield Trading L.P. to the extent that two entities together may maintain maximum net positions of twice the speculative position limits contained in Reg. ?150.2. However, the no-action position is conditioned upon neither individually exceeding the applicable spot-month, single-month, or all-futures speculative limits and upon both in the aggregate not exceeding the applicable spot-month limit. |
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| 90-14 ; Regulation 30.10;; No-Action The Division of Trading and Markets permitted a U.S. IB and a U.K. firm to hold meetings in the U.S. with 12 large institutions in order to discuss investing in financial futures traded on the London Exchange, without the U.K. firm having to register as an FCM. (T&M) |