CFTC Staff Letters

CFTC Staff Letters provides Letters from 2008 and later. For Letters published before 2008 visit the Letters Archive page.

PDF Description
PDF Image 26-26 Letter Type: No-Action
Division: DCR
Regulation Parts: 1.49, 22.9
Tags: Cleared Swaps, Clearing, Collateral, DCO, FCM, Customer Funds
Issuance Date:
Description: Eurex Clearing no-action letter regarding the use of Clearstream Banking S.A. as a central securities depository.
See also: Request Letter
Requester(s): EUREX
PDF Image 26-25 Letter Type: No-Action
Division: MPD
Regulation Parts: 4d, 4k, 3.10, 3.12
Tags: IB, Registration, Associated Persons
Issuance Date:
Description: MPD no-action position, subject to certain specified conditions, on introducing broker and associated person registration for passive software providers.
Requester(s): CFTC
PDF Image 26-24 Letter Type: No-Action
Division: DMO
Regulation Parts: 15, 16, 17, 17.01
Tags: Large Trader, Reporting, Ownership and Control
Issuance Date:
Description: No-action position concerning application of the Commission’s reporting regulations applicable to exclusively self-cleared contracts to contracts traded by a mix of direct and intermediated participants.
See also: Request Letter
Requester(s): ELECX
PDF Image 26-21 Letter Type: No-Action
Division: DMO
Regulation Parts: 38.3, 40.1
Tags: DCM, Dormancy
Issuance Date:
Description: Kraken Derivatives Exchange Inc. (f/k/a Small Exchange, Inc.) – Extension of Time-Limited No-Action Position with respect to Certain Provisions under the Commission’s Dormancy Framework for Registered Entities.
See also: Request Letter
Requester(s): SMFE
PDF Image 26-20 Letter Type: No-Action
Division: DMO, DCR, MPD
Regulation Parts: 2(h)(1), 2(h)(1)(A), 2(h)(8), 1, 36, 37.3, 43, 50
Tags: Clearing, Clearing Requirement, DCM, DCO, IB, Portfolio, Recordkeeping, Registration, Reporting, Risk, SEF, Swap, Swaps, Trade Execution, Trade Execution Requirement, Part 43, SEF Registration, Swap Execution Facility, Exempt SEF, Part 50, Part 36, Part 1
Issuance Date:
Description: Provides, subject to certain conditions, no-action positions for post-trade risk reduction service providers for failure to register as a swap execution facility, and for those entering into swaps that are subject to the swap clearing requirement and trade execution requirement.
See also: Request Letter
Requester(s): CAPLLC, QTL, TRO
PDF Image 26-19 Letter Type: No-Action
Division: DMO
Regulation Parts: 40.6
Tags: Perpetual Futures, Perpetual Style Futures, Contract Terms and Conditions Amendments
Issuance Date:
Description: The Commodity Futures Trading Commission’s Division of Market Oversight today announced it has issued no-action relief to designated contract markets seeking to convert their existing perpetual style digital commodity futures contracts into true digital commodity perpetual futures.
See also: Request Letter 1   Request Letter 2  
Requester(s): BTNL, COINBASE
PDF Image 26-18 Letter Type: No-Action
Division: DMO
Regulation Parts: 38.3, 40.1
Tags: DCM, Dormancy
Issuance Date:
Description: Cboe Digital Exchange, LLC - Time-Limited No-Action Position with respect to Certain Provisions under the Commission’s Dormancy Framework for Registered Entities
See also: Request Letter
Requester(s): ERISDCM
PDF Image 26-17 Letter Type: No-Action, Interpretative
Division: MPD
Regulation Parts: 30.1, 30.7
Tags: FCM, Foreign Future, Margin, Foreign Broker, Digital Commodities, Payment Stablecoins
Issuance Date:
Description: Staff Interpretative Letter Regarding the Categorization of Deribit Perpetuals as Foreign Futures and No-Action Position Regarding Digital Commodities and Payment Stablecoins Deposited to Margin Customer Positions with a Foreign Broker Under a Right of Re-Use
See also: Request Letter
Requester(s): CFM
PDF Image 26-14 Letter Type: No-Action
Division: DMO
Regulation Parts: 38.8, 38.10, 38.951, 39.20, 43, 45
Tags: Reporting, Swap, Swap Data, Swaps, Event Contract, Part 43, Part 45
Issuance Date:
Description: No-action position with respect to Part 43 and Part 45 reporting, as well as related sections of Parts 38 and 39, for certain binary and variable payout event contracts.
See also: Request Letter 1   Request Letter 2   Request Letter 3   Request Letter 4  
Requester(s): CFTC
PDF Image 26-13 Letter Type: No-Action
Division: DMO, DCR
Regulation Parts: 38.8, 38.10, 38.951, 39.20, 43, 45
Tags: Fully-collateralized, Recordkeeping, Reporting, Swap, Swap Data, Swaps, Event Contract, Part 43, Binary Option, Part 45
Issuance Date:
Description: The Divisions will not recommend that the Commission initiate an enforcement action against Railbird, Bitnomial, or their participants, for failure to comply with Commission regulations 38.8(b), 38.10, 38.951 (only to the extent that regulation 38.951 requires compliance with Part 45 of the CFTC’s regulations), and 39.20(b)(2), as well as the applicable provisions of Parts 43 and 45 of the CFTC’s regulations, or the requirements of the relevant CEA provisions pursuant to which the Relevant Regulations were promulgated, with respect to Railbird Contracts, subject to certain conditions.
See also: Request Letter
Requester(s): BTNL CLEAR, RAILBIRDX