CFTC Staff Letters

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

Staff No-Action position regarding transfer of customer-owned securities by US FCM to a foreign broker.

No-action relief to DCOs, giving additional six months to begin reporting continuation data on swaps accepted for clearing, subject to certain conditions. Additional relief to all reporting counterparties on 11 new data elements for a period of three months subject to certain conditions.

No-action letter permitting a provision of the inter-affiliate exemption from required clearing (Commission regulation 50.52(b)(4)(ii)) to be relied upon for swaps executed between certain U.S. swap market participants and their affiliated counterparties located in Australia or Mexico, analogous to how this provision has been available for swaps with affiliated counterparties located in the European Union, Japan, and Singapore.

No-action position regarding the consolidation of separate risk disclosure statements contained in Regulation 1.55(b) and Appendix A to Regulation 1.55 into a single risk disclosure statement

No-action letter again 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).

No-action letter extending time-limited no-action relief, providing that the Division of Market Oversight will not recommend that the Commission take enforcement action against any eligible affiliate counterparty that executes a swap transaction with another eligible affiliate counterparty without complying with section 2(h)(8) of the Act.

Time-limited no-action relief from certain requirements of Part 45 and Part 46 of the Commission’s regulations for certain swap dealers and major swap participants established under the laws of Australia, Canada, the European Union, Japan or Switzerland

No-Action relief from the timing requirements of Commission Regulation 3.3(f)(2) relating to annual reports by chief compliance officers.

No-Action relief from the timing requirements of Commission Regulation 3.3(f)(2) relating to annual reports by chief compliance officers.