CFTC Staff Letters

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing and certification requirements in Regulations 4.22(c) and 4.22(d) for fiscal year 2013 and permission to file uncertified annual reports in lieu thereof and attached a waiver from the non-proprietary participant.

The investment manager of a cash collateralized loan obligation (CLO) transaction requested, and DSIO granted pursuant to Regulation 140.99, a no action position from DSIO that it would not recommend that the Commission commence an enforcement action for its failure to register as a commodity trading advisor with respect to the advice provided to the CLO.

The CPOs of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing requirements in Regulation 4.22(c) for fiscal year 2013 and requested to be permitted to file with NFA and distribute to participants an annual report for the pool covering the period from January 1, 2013 to March 7, 2014, when the pool permanently ceased trading.

No-action relief regarding format of acknowledgment letters and format and content of daily reports for DCO winding down operations in anticipation of vacating its DCO registration.

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing and certification requirements in Regulations 4.7(b)(3) and 4.22(d). The CPO requested permission to file an uncertified annual report for fiscal year 2013.

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing and certification requirements in Regulations 4.7(b)(3) and 4.22(d) for fiscal year 2013.

The CPOs of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing requirements in Regulation 4.22(c) for fiscal year 2013 and requested to be permitted to file with NFA and distribute to participants an annual report for the pool covering the period from January 1, 2013 to March 24, 2014, when the pool permanently ceased trading.

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing and certification requirements in Regulations 4.7(b)(3) and 4.22(d) and permission to distribute and file a 15-month annual report covering the period from inception of trading on October 1, 2013 through December 31, 2014.

The Division of Clearing and Risk and Division of Market Oversight (together, “the Divisions”) issued a no-action letter providing time-limited and specific relief for designated contract markets (“DCMs”) from compliance with certain requirements of Commission Regulation 38.152, including a prohibition against certain abusive trading practices, including pre-arranged trading.

The Division of Swap Dealer and Intermediary Oversight granted exemptive relief pursuant to Commission regulations 4.12(a) and 140.93 to a commodity pool operator of several commodity pools operating pursuant to an exemption under Commission regulation 4.7 whose only participants are principals, senior employees, portfolio managers of the commodity pool operator, and trusts controlled by the principals of the commodity pool operator from the requirement to have an independent public accountant audit the financial statements in the commodity pool’s annual report for fiscal year 2013 and going forward pursuant to Commission regulation 4.22(d).