CFTC Staff Letters

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from Regulations 4.7(b)(3) and 4.22(d), which require the filing and distribution of audited financial statements, for fiscal year 2015 and requested to be permitted to file with NFA and distribute to participants audited financial statements for the pool covering the period from July 21, 2015 to December 31, 2016.

No-Action Relief from the Timing Requirements of Commission Regulation 3.3(f)(2) Relating to Annual Reports by Chief Compliance Officers for Deutsche Bank AG.

No-Action Relief from the Timing Requirements of Commission Regulation 3.3(f)(2) Relating to Annual Reports by Chief Compliance Officers for Commerzbank AG.

Extension of Time-Limited No-Action Relief with Respect to Certain Commodity Exchange Act Provisions That May Apply to Southwest Power Pool, Inc. and/or Its Participants.

The CFTC’s Division of Clearing and Risk (the “Division”) issued a no-action letter providing limited no-action relief for derivatives clearing organizations (“DCOs”) that are registered with the Commission and are authorized to operate as central counterparties (“CCPs”) in the EU from the application of Commission regulations to discrete aspects of their non-U.S. clearing activities.

The Division of Market Oversight is issuing a no-action letter that extends Letter No. 15-25 and provides relief from: (1) the requirement that a SEF obtain documents that are incorporated by reference in a confirmation issued under Commission Regulation 37.6(b) prior to issuing the confirmation; (2) the requirement that a SEF maintain such documents as records; and (3) the requirement that a SEF report terms contained in such documents that are confirmation data.

Advisory to Futures Commission Merchants reminding them of key risk management program requirements and sharing observed examples of practices for implementing an effective program.

The Division of Swap Dealer and Intermediary Oversight took a no-action position with respect to IBs guaranteed by a certain FCM, where the IBs would introduce ECP swap counterparties to each other, without opening or carrying customer accounts with the guarantor FCM. For uncleared swaps, no FCM would be involved in the transaction, and for cleared swaps, each counterparty would use an FCM for clearing that the counterparty had selected. The guarantor FCM would remain well-capitalized for the risk undertaken, and would be jointly and severally liable for all obligations of each of the guaranteed IBs with respect to their solicitation of swaps orders.

DSIO response to industry questions on Form CPO-PQR FAQ.

Exemptive relief that was provided in CFTC Staff Letter 14-49 was granted with respect to additional proprietary commodity pools operated by a 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.