CFTC Staff Letters

The no-action letter provides relief to a derivatives clearing organization (DCO) that is dually registered as a securities clearing agency for failure to enforce certain of its clearing member requirements. Under this relief, the DCO may waive the applicability of certain of its bylaws and rules to facilitate a transaction involving the transfer, assignment and assumption of the securities correspondent clearing business of one clearing member to another.

The Division of Swap Dealer and Intermediary Oversight took a CPO and CTA registration no-action position with respect to a registered investment adviser that acted as the sponsor and investment manager for a pension plan group trust. Each of the plans participating in the group trust was within the categories of plans excluded under Regulation 4.5 from the “pool” definition.

No-Action Relief: U.S. Bank Wholly Owned by Foreign Entity May Calculate De Minimis Threshold Without Including Activity From Its Foreign Affiliates.

Relief for Certain Swap Dealers, De Minimis Dealers, Agent Affiliates, and Associated Persons from Registration as an Introducing Broker under Section 4d or a Commodity Trading Advisor under Section 4m of the Commodity Exchange Act, and Interpretation that Certain Employees of De Minimis Dealers are not an Introducing Broker as defined in Section 1a(31) of the Commodity Exchange Act.

Extension of Temporary Registration Relief under CFTC Staff Letter No. 12-15 for Certain Associated Persons.

Temporary Registration Relief for Commodity Pool Operators and Commodity Trading Advisors that Must Register as a Result of Amended CFTC Regulation 4.5 and Rescinded CFTC Regulation 4.13(a)(4).

No-Action Relief for Investment Pools Investing in Certain Securitization Vehicles Formed Prior to October 12, 2012.

Relief regarding the reporting of swap transaction data.

Time-Limited No-Action Relief from the Reporting of Certain Non-Reporting Counterparty Information Pursuant to Parts 45 and 46

Time Limited No-Action Relief: Compo Equity Total Return Swaps.