CFTC Staff Letters

This no-action letter provides relief from compliance with certain position aggregation requirements under Commission Regulation 150.4.   

Commission Regulation 30.7 – Staff No-Action Position Regarding Futures Commission Merchant’s Deposit of Customer-Owned Securities as Margin with a Foreign Broker.  

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).  

No-action relief granted to an entity (Ltd.) from registering as a CPO 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 registering as a CPO 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 from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.  

Commission Regulation 1.16 – Staff no-action position regarding compliance with Public Company Accounting Oversight Board requirement to communicate “critical audit matters” in Accountants’ Unqualified Audit Opinions.

Conditional, time-limited no-action relief to an entity for not counting certain loan-related swaps towards its swap dealer de minimis threshold (under paragraph (4) of the “swap dealer” definition in Regulation 1.3).

Commission Regulation 1.17 – Staff no-action position regarding the treatment of operating leases caused by a change in accounting principles.

Extension of time-limited no-action relief for Shanghai Clearing House with regard to Section 5b(a) of the Commodity Exchange Act and Commission Regulations thereunder.