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
92-10 PDF Image; Regulations 32.2 and 32.4;; No-Action
The Division of Trading and Markets granted no-action relief to Philbro Energy, Inc., to permit a commodity merchant/processor's offer and sale of options on agricultural commodities to certain commercial counterparties, including qualified processors, manufacturers and merchants of agricultural products and byproducts with assets in excess of $10 million and/or a net worth in excess of $5 million.
92-09 PDF Image; Regulation 4.21;; No-Action
The Division of Trading and Markets permitted a CPO to use a two-part Disclosure Document, subject to certain conditions – one of which was that investors were given both parts of the Document at the same time. (T&M)
92-08 PDF Image; Section 4m(1);; No-Action
The Division of Trading and Markets granted CPO registration no-action relief to the board of trustees of a union’s death benefit fund, where the fund’s assets would be in invested in commodity interests for hedging purposes. (T&M)
92-7 PDF Image; Sections 4a, 5a(8), 6(a), 6b, 6c, 6(b), 6(c) and Regulations 150.2 and 150.3;; No-Action
The Division of Economic Analysis granted no-action relief to CBT regarding enforcement of the single-month speculative position limit in CBT's corn, oats, soybeans, soybean meal, soybean oil and wheat futures contracts for positions which are part of an inter-crop year spread. Pursuant to the no-action letter, inter-month spread positions would be permitted to levels equaling twice the individual-month limit regardless of the crop-year of the individual months comprising the spread position. The no-action position was limited in its effect until September 30, 1992.
92-06 PDF Image; Regulations 4.31 and 4.32;; No-Action
The Division of Trading and Markets granted interim disclosure and recordkeeping no-action relief to a CTA with respect to its Regulation 4.7 clients pending the adoption and effectiveness of Regulation 4.7 by the Commission. (T&M)
92-05 PDF Image; Regulation 1.55;; No-Action
The Division of Trading and Markets permitted FCMs to obtain a single acknowledgement (rather than multiple acknowledgements) from specified categories of institutional and highly accredited investors. (T&M)
92-04a PDF Image; Section 5;; No-Action
The Division of Trading and Markets granted no-action relief to the University of Iowa to permit the operation of a non-profit electronic market (the Iowa Electronic Markets) organized by the faculty of a university for the purpose of academic research. Relief from the CEA and CFTC rules was given with regard to submarkets concerning political elections. (T&M)
92-04 PDF Image; Section 4m(1);; No-Action
The Division of Trading and Markets granted CPO registration no-action relief to an international labor union operating a general fund, where the fund’s assets would be invested in commodity interests for hedging purposes. (T&M)
91-8 PDF Image; Section 5;; No-Action
The Division of Trading and Markets granted no-action relief to Reuters Information Services, Inc. to permit a subsidiary of a corporation with limited liability under the laws of two foreign countries to operate a computerized system for trading foreign currencies and the U.S. dollar for actual delivery, without seeking designation as a contract market or otherwise complying with the CEA, provided that (1) the subsidiary's operation of the system is strictly limited to facilitating spot foreign currency transactions by matching buy and sell orders between its commercial bank subscribers; (2) the subsidiary does not offer a means to liquidate performance obligations entered into over the system through offset and such obligations will be terminable only through counterparty consent; and (3) the subsidiary does not involve itself in the process of transferring currency between principals aside from enabling the exchange of pre-programmed settlement instructions as described.
91-1 DEA PDF Image; Sections 4a, 5a(8), 6(a), 6b, 6c, 6(b), 6(c) and Regulations 150.2 and 150.3;; No-Action
The Division of Economic Analysis granted temporary no-action relief to the Chicago Board of Trade to permit it to not enforce individual month speculative position limits in soybean oil contracts to the extent that positions that exceed such position limits are spread or arbitrage positions between single months of the soybean oil futures contract outside of the spot month; provided however, that such spread or arbitrage positions, when combined with any outright positions in the single month do not exceed 1,080 contracts. This no-action position was only effective until August 31, 1991.