CFTC Staff Letters

Extension of previously issued no-action.

The Division of Clearing and Risk issued a letter stating that it will not recommend that the Commission take enforcement action against Singapore Exchange Derivatives Clearing Limited (SGX-DC) clearing members for failing to comply with the Commodity Exchange Act Section 4d(f)(1) registration requirements in carrying existing positions and accepting for clearing offsetting positions in certain commodity swaps for U.S. customers or customers of FCMs that clear through an FCM omnibus customer account; or SGX-DC for engaging in activities related to its clearing members carrying and accepting for clearing such customer positions.

Extension of joint no-action relief granted by DCR and DMO on September 27, 2013, allowing LCH.Clearnet Ltd to clear contracts listed for trading on Nodal Exchange LLC.

Extension of no-action relief granted by DCR on September 23, 2013, allowing LCH.Clearnet Ltd to clear swaps executed on designated contract markets and swap execution facilities.

Staff No-Action Relief: Revised Relief from the De Minimis Threshold for Certain Swaps with Utility Special Entities

Time-Limited No-Action Relief for Certain Members of a Designated Contract Market from the Requirement to Record Oral Communications, Pursuant to Commission Regulation 1.35(a), in Connection with the Execution of Swap Transactions

No-Action Relief from Compliance with Certain Requirements of Commission Regulation 3.3 Relating to the Chief Compliance Officer Annual Report (Mitsui & Co. Precious Metals, Inc.)

Extension of Time-Limited No-Action Relief with respect to Swaps Trading on Certain Multilateral Trading Facilities Overseen by Competent Authorities Designated by European Union Member States

The Division of Swap Dealer and Intermediary Oversight confirmed the availability of Staff Letter 00-10, which provided CPO registration relief to a universitys cooperative extension service, its agents and employees, permitting them to offer courses that would allow certain students to trade commodity interests through participation in a trading club, notwithstanding certain amendments to the course and trading club criteria.

The Division of Swap Dealer and Intermediary Oversight (Division) took a CPO registration no-action position with respect to the operation of certain collective trading vehicles by either of two corporations (A and B) entirely controlled by a non-profit corporation (C) that is the coordinating organization for a denomination’s churches. The collective trading vehicles would commingle assets of church plans (within the definition of Regulation 4.5) associated with the denomination’s churches, together with endowments and other assets of certain non- profit corporations entirely controlled by C. Although the collective trading vehicles would be pools, the Division believed that requiring CPO registration would serve no substantial regulatory purpose because persons who would be subject to background checks and proficiency examinations would already have been vetted and hired by A, B or C, and because any Disclosure Document would be delivered by A or B to the other or to C.