CFTC Staff Letters

No-action relief granted to ensure the continued availability, following Brexit, of regulatory relief under certain existing CFTC comparability determinations and exemption orders originally issued by the CFTC for EU entities, while CFTC staff undertakes an analysis of UK law in order to make appropriate recommendations of comparability or exemption to the CFTC.

Granting time-limited no-action relief to [“A”] permitting its Irish bank subsidiary, [“B”], to act as reporting counterparty for [“B”]’s swaps with U.S. persons that are not swap dealers (“SDs”) or major swap participants (“MSPs”), notwithstanding the allocation of reporting responsibility set forth in Commission Regulation 45.8(e).

No-Action Position for Off-SEF Swaps Executed Pursuant to Prime Brokerage Arrangements

No-action relief granted to an entity (Ltd.) from CPO registration under CEA Section 4m(1) with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.

No-action relief granted to an entity (LLC) from CPO registration under CEA Section 4m(1) with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.

CPO exempt from the requirement to provide quarterly account statements within 30 ends of the end of each quarter, provided that the CPO provides monthly account statements within 45 days of the end of each month.  

No-Action relief granted to an entity from registering as a CPO or CTA with regard to managing the investing activities of its affiliate, which owns mineral and royalty interests in crude oil and natural gas properties.

Exemptive relief granted to a CPO to permit the CPO to provide monthly account statements to participants in specific commodity pools it operates within 45 days of the month end, rather than quarterly account statements within 30 days of the quarter end as required by Commission Regulation 4.7(b)(2).

No-Action relief granted to the general partner of a commodity pool from the Commission’s registration requirements, and to delegate certain of its responsibilities to a registered CPO.

Exemptive relief granted to a CPO to permit the CPO to provide monthly account statements to participants within 45 days of the month end rather than quarterly account statement within 30 days of the quarter end pursuant to Commission regulation 4.7(b)(2