CFTC Staff Letters

No-Action letter permitting, subject to certain conditions, the CPO of a pool organized as a UCITS that holds funds contributed by employees of its U.S. management company to operate said pool and its subfunds without registering as a CPO.

The CPO of two commodity pools, both exempt under Regulation 4.7, requested exemptive relief from the annual report requirement in Regulation 4.7(b)(3), to allow the filing of an annual report for the pools for the period from October 2, 2014, the date the pools began trading, to December 31, 2015; DSIO granted relief pursuant to Regulations 4.12(a) and 140.93 conditioned upon the future filing and distribution of a certified Annual Report for that time period.

Exemptive relief granted to a CPO to permit the CPO to provide monthly account statements to a pool’s 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).

Exemptive relief granted to a CPO of a pool that had all of its participants redeem out in 2014 from the audit requirements of Commission regulation 4.22(d) with respect to the financial statements in the 2014 annual report of the pool that is filed with NFA.

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.