CFTC Staff Letters

No-action relief granted from CPO and CTA registration to an entity that uses swaps in connection with its acquisition of biopharmaceutical royalties.

Partial continuation of no-action positions to facilitate physical separation of registrant personnel in response to the COVID-19 pandemic

No-action positions for floor brokers and introducing brokers from oral recordkeeping requirements and designated contract markets from audit trail requirements in continued response to the COVID-19 pandemic

Approval letter issued to the National Futures Association with regard to Swap Dealer captial model requirements and review program.

Time-Limited No-Action relief to FCMs from Regulation 1.25 for Investments in Securities with an Adjustable Rate of Interest Benchmarked to the Secured Overnight Financing Rate

Temporary no-action relief for registered derivatives clearing organizations from the amended daily reporting requirements in CFTC Regulation 39.19. This relief expires on January 27, 2022.

Extension of time-limited no-action relief for Shanghai Clearing House with regard to Section 5b(a) of the Commodity Exchange Act and Commission Regulations thereunder.

No-action letter extending relief from section 2(h)(8) of the Commodity Exchange Act for any eligible affiliate counterparty that executes a swap transaction with another eligible affiliate counterparty

No-action relief permitting an FCM clearing member to, in the event of a customer default, effect swap transactions pursuant to LCH’s default rules and procedures without executing such transactions on a SEF, exempt SEF, or DCM as required by the trade execution requirement.

The Divisions do not interpret Sections (2)(h)(1) and 2(h)(8) of the CEA as subjecting to the clearing and trade execution requirements certain swaps transactions entered into by a DCO to reduce and manage the risk associated with a clearing member default.