CFTC Staff Letters

Exemptive relief granted to a CPO of a pool from the audit requirements of Commission regulation 4.22(d) with respect to the financial statements in the 2014 annual report of the pool. The CPO has provided a waiver from the sole outside participant of the pool.

Exemptive relief granted to a CPO of a pool from the audit requirements of Commission regulation 4.22(d) with respect to the financial statements in the 2014 annual report of the pool. The CPO has provided a waiver from the sole participant of the pool.

Exemptive relief granted to a CPO of a pool from the audit requirements of Commission regulation 4.22(d) with respect to the financial statements in the 2014 annual report of the pool. The CPO has provided a waiver from the sole participant of the pool.

Exemptive relief granted to a CPO of several pools organized in a three-level master-feeder structure from the audit requirements of Commission regulation 4.22(d) with respect to the financial statements in the 2014 annual reports of the pools.

Further extension of no-action relief originally granted by DMO on December 17, 2012 (previously extended on June 26, 2013 and June 30, 2014) to SD and MSP reporting counterparties for cleared swaps from valuation data reporting required in section 45.4(b)(2)(ii) of the Commission’s regulations.

No-Action Relief from Introducing Broker and Commodity Trading Advisor registration for persons located outside the United States in connection with certain activities for customers that are International Financial Institutions.

Exemptive relief that was provided in CFTC Staff Letter 14-49 was granted with respect to: (1) additional proprietary commodity pools operated by a CPO referenced in that letter; and (2) a proprietary commodity pool operated by another CPO referenced in that letter. The CPOs provided the same representations provided in CFTC Staff Letter 14-49 and represented that they would comply with the conditions of the relief provided in that letter.

Exemptive relief granted to a CPO of a pool from the audit requirements of Commission regulation 4.22(d) with respect to the financial statements in the 2014 annual report of the pool. The participants in the pool are the COO of the CPO and the COO’s self-directed IRA and the CPO has provided waivers from the participants.

Exemptive relief granted to a CPO of a pool from the audit requirements of Commission regulation 4.22(d) with respect to the financial statements in the annual reports of the pool. The participants in the pool are three charitable remainder trusts formed by the sole owner and CEO of the CPO, who is also the sole income beneficiary of the trusts. The trustee of the trusts is the President of the CPO. The CPO has provided a waiver from the trustee.

Exemptive relief that was provided in CFTC Staff Letters 14-35 and 14-36 with respect to the requirements of Commission regulations 4.21, 4.22, and 4.25 was extended to the successor CPO of the trusts and series in those letters, subject to certain conditions, including the following: (1) the material business terms of the trusts and series do not change; (2) the investment experience of the shareholders does not change; (3) the only material change is the substitution of the CPO; (4) the representations made by the CPO in CFTC Letters 14-35 and 14-36 remain applicable; and (5) the successor CPO complies with the terms and conditions for relief set forth for the CPO in CFTC Letters 14-35 and 14-36.