CFTC Staff Letters

No-action relief granted to an entity from CPO registration with respect to a commodity pool for which it serves as trustee; provided, that it delegates the CPO responsibilities to a registered CPO, subject to certain conditions.

No-action relief granted to an entity from CPO registration with respect to several commodity pools for which it serves as trustee; provided, that it delegates the CPO responsibilities to a registered CPO, subject to certain conditions.

No-action relief for non-U.S. persons that are neither guaranteed affiliates nor conduit affiliates of a U.S. person from the requirement to count swaps with international financial institutions towards the de minimis thresholds for the swap dealer and major swap participant definitions.  

The Division of Swap Dealer and Intermediary Oversight provided no-action relief from CPO and CTA registration to the trustee of a pension plan group trust comprised solely of pension plans that are “not construed to be pools” under Regulation 4.5(a)(4)(i)-(iii).

No-Action 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.

No-Action Extension of no-action relief originally granted by DMO on December 19, 2016 to counterparties clearing swaps through derivatives clearing organizations acting under exemptive or no-action relief from certain reporting obligations for cleared swaps under Part 45 of the Commissions regulations.

No-Action  CFTC staff issues time limited no-action relief to Shorcan Energy Brokers Inc. and its associated persons for introducing broker and associated person registration.

Staff no-action position regarding the treatment of a deferred tax liability caused by a change in accounting principles.

No action letter extending relief from section 2(h)(8) of the Commission Exchange Act for any eligible affiliate counterparty that executes a swap transaction with another eligible affiliate counterparty.

No-action letter extending the time-limitation contained in an alternative compliance framework available to certain affiliated counterparties pursuant to Commission regulation 50.52(b)(4)(ii)-(iii), extending the time-limitation permitting certain affiliated counterparties located in Australia and Mexico to use the compliance framework under regulation 50.52(b)(4)(ii), and providing analogous relief to certain affiliated counterparties located in Canada, Hong Kong, and Switzerland.