CFTC Staff Letters

The Division of Swap Dealer and Intermediary Oversight provided no-action relief to the general partners of two commodity pools from registering as a CPO under Section 4m(1) of the Commodity Exchange Act, and allowed an affiliated CPO (“designee”) to serve as the CPO of the pools instead, where, among other things: (1) the general partners and the designee are under common ownership and control; (2) the general partners have delegated all of their management authority to the designee; (3) the general partners do not engage in the solicitation of investors for the pools and do not manage property of the pools; and (4) each of the general partners and the designee executed and submitted to the Division a written acknowledgement by which they undertake joint and several liability for any violation of the Act or the Commission’s regulations.

Obligation of Futures Commission Merchants, Clearing Members and Foreign Brokers to Report Omnibus Account Information in a Timely Manner as Required by Commission Regulation 17.04(a).

Reporting Block Trade Volume Data Pursuant to Commission Regulation 16.01.

No-Action Relief with Respect to Email as an Accepted Form of Transmitting Form 304 Reports for Call Cotton.

Time-Limited Relief for Swap Dealers and Major Swap Participants from Compliance with Business Conduct Standards in Foreign Exchange Transactions with a Settlement Cycle of No More than Seven Local Business Days.

Relief for Swap Dealers and Major Swap Participants Regarding the Obligation to Provide Certain Disclosures for Certain Transactions Under Regulation 23.431.

Time Limited Relief for Swap Dealers in Connection with Prime Brokerage Arrangements.

Time-Limited No-Action Relief for Swap Counterparties that are not Swap Dealers or Major Swap Participants, from Certain Swap Data Reporting Requirements of Parts 43, 45 and 46 of the Commission’s Regulations.

No-Action Relief for Swaps Between Affiliated Counterparties That Are Neither Swap Dealers Nor Major Swap Participants from Certain Swap Data Reporting Requirements Under Parts 45, 46, and Regulation 50.50(b) of the Commission’s Regulations.

Staff No-Action Relief from the Reporting Requirements of 32.3(b)(1) of the Commissions Regulations, and Certain Recordkeeping Requirements of 32.3(b), for End Users Eligible for the Trade Option Exemption.