CFTC Staff Letters

No-action letter permitting, subject to certain conditions, the CPO of a pool comprised solely of sophisticated institutions that do not invest in the pool for the primary purpose of obtaining an investment return, but rather as part of their respective mandates to promote sustainable economic development to operate said pool without registering as a CPO.

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

Exemptive relief from the provisions of Commission Regulations 4.7 and 4.22 to prepare an onshore feeder fund’s financial statements in accordance with U.S. GAAP

Exemptive relief from the provisions of Commission Regulations 4.7 and 4.22 to prepare an onshore feeder fund’s financial statements in accordance with U.S. GAAP

Exemptive relief from the provisions of Commission Regulations 4.7 and 4.22 to prepare an onshore feeder fund’s financial statements in accordance with U.S. GAAP

Staff No-Action position regarding transfer of customer-owned securities by US FCM to a foreign broker.

DSIO’s interpretation of Regulation 23.451 clarifying staff’s view that a swap dealer’s contributions for transition or inaugural expenses incurred by a successful candidate are only covered by the rule to the extent that such expenses are incurred by a successful candidate for a position as an official of a governmental Special Entity.

No-action relief to DCOs, giving additional six months to begin reporting continuation data on swaps accepted for clearing, subject to certain conditions. Additional relief to all reporting counterparties on 11 new data elements for a period of three months subject to certain conditions.

No-action letter permitting a provision of the inter-affiliate exemption from required clearing (Commission regulation 50.52(b)(4)(ii)) to be relied upon for swaps executed between certain U.S. swap market participants and their affiliated counterparties located in Australia or Mexico, analogous to how this provision has been available for swaps with affiliated counterparties located in the European Union, Japan, and Singapore.

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).