CFTC Staff Letters

Conditional No-Action Relief to Eurex Clearing AG and its FCM Clearing Members to hold customer margin in the form of securities at Clearstream Banking AG

This no-action letter provides relief from compliance with certain position aggregation requirements under Commission Regulation 150.4.   

Commission Regulation 30.7 – Staff No-Action Position Regarding Futures Commission Merchant’s Deposit of Customer-Owned Securities as Margin with a Foreign Broker.  

No-action relief granted to an entity (Ltd.) from registering as a CPO with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.

No-action relief granted to an entity (LLC) from registering as a CPO with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.  

No-action relief granted to an entity from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.  

Commission Regulation 1.16 – Staff no-action position regarding compliance with Public Company Accounting Oversight Board requirement to communicate “critical audit matters” in Accountants’ Unqualified Audit Opinions.

Conditional, time-limited no-action relief to an entity for not counting certain loan-related swaps towards its swap dealer de minimis threshold (under paragraph (4) of the “swap dealer” definition in Regulation 1.3).

Commission Regulation 1.17 – Staff no-action position regarding the treatment of operating leases caused by a change in accounting principles.

Extension of time-limited no-action relief for Shanghai Clearing House with regard to Section 5b(a) of the Commodity Exchange Act and Commission Regulations thereunder.