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 24-02 Letter Type: No-Action
Division: MPD
Regulation Parts: 23.431
Tags: Compliance, Counterparty, Disclosures, Swap Dealer, External Business Conduct, Business Conduct Standards, Documentation, SOFR
Issuance Date:
Description:

No-action position for registered swap dealers and major swap participants that enter into certain swaps referencing the Secured Overnight Financing Rate (described in the letter) relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission regulation 23.431(a)(3)(i).


See also: Request Letter
Requester(s): ARRC
PDF Image 24-01 Letter Type: No-Action, Exemption
Division: DCR
Regulation Parts: 4d(f), 1.20, 1.49, 22.5
Tags:
Issuance Date:
Description:

No-action relief for LCH SA with regard to Regulations 1.20(g)(4) and 22.5, and an exemption from the requirements of Regulation 1.49(d)(3) for customer accounts held at the Banque de France.


Requester(s): LCHSA
PDF Image 23-15 Letter Type: No-Action
Division: DMO
Regulation Parts: 43, 43.4, 43.6
Tags: Block Trades, Reporting, SDR, Swap Data, Swaps, Part 43
Issuance Date:
Description:

DMO is extending a time-limited no-action position with respect to the compliance date for the November 25, 2020 amendments to certain rules pertaining to block thresholds and cap sizes in Part 43.
Request Letter No. 2
Request Letter No. 3


See also: Request Letter
Requester(s): CMESDR, DTCC, ICE SDR, KOR
PDF Image 23-14 Letter Type: No-Action
Division: DMO
Regulation Parts: 17, 18, 20
Tags: Reporting, Ownership and Control, Part 17, Part 18, Part 20
Issuance Date:
Description:

Extension of conditional time-limited no-action position for filing certain information for ownership and control reports required by Parts 17, 18, and 20 of the Commission's regulations


See also: Request Letter
Requester(s): CMC, FIA, ISDA
PDF Image 23-13 Letter Type: No-Action
Division: DCR, MPD
Regulation Parts: 39.13
Tags: Risk Management, Separate Account Treatment
Issuance Date:
Description:

Accordingly, the conditional no-action relief with respect to Regulation 39.13(g)(8)(iii) is now further extended until the earlier of (a) June 30, 2024 or (b) the effective date of any final Commission action relating to Regulation 39.13(g).


See also: Request Letter
Requester(s): FIA
PDF Image 23-12 Letter Type: No-Action
Division: DCR
Regulation Parts: 5b(a)
Tags: Clearing, Exempt DCO
Issuance Date:
Description:

Extension of time-limited no-action position for Taiwan Futures Exchange with regard to Section 5b(a) of the Commodity Exchange Act and Commission regulations thereunder.


See also: Request Letter
Requester(s): TAIFEX
PDF Image 23-11 Letter Type: No-Action
Division: MPD
Regulation Parts: 23.105
Tags: Financial Reports, Swap Dealer
Issuance Date:
Description:

Time limited no-action relief from regulation 23.105(p) for certain alternative financial reporting by SDs subject to the capital requirements of a prudential regulator.


See also: Request Letter
Requester(s): ISDA, SIFMA
PDF Image 23-10 Letter Type: No-Action
Division: MPD
Regulation Parts: 3, 4
Tags: Commodity Pool, CPO, CTA, Registration, Swaps
Issuance Date:
Description:

No-action position from CPO/CTA registration granted to an entity that uses foreign exchange swaps in managing the risks of its biopharmaceutical royalties business.


See also: Request Letter
Requester(s): ROYALTY
PDF Image 23-09 Letter Type: No-Action
Division: DMO, DOD
Regulation Parts: 43, 43.3, 45, 45.4
Tags: Reporting, Swaps, LIBOR, Part 43, Part 45
Issuance Date:
Description:

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) and Division of Data (DOD) take a no-action position regarding certain Part 43 and Part 45 swap reporting obligations in relation to the cessation or non-representativeness of USD LIBOR and other rates on June 30, 2023.


See also: Request Letter
Requester(s): ARRC
PDF Image 23-08 Letter Type: No-Action
Division: MPD
Regulation Parts: 1.20, 1.32
Tags: FCM, Reporting, Segregated, Segregation, Customer Funds
Issuance Date:
Description:

No-Action position regarding the deposit and holding of customer funds by a registered FCM under certain circumstances with Taiwan Banks


See also: Request Letter
Requester(s): ADMIS