CFTC Staff Letters

Relief for Swap Dealers and Major Swap Participants from Compliance with Regulation 23.22(b) with Respect to: (1) Non-Domestic Associated Persons who Deal only with Non-Domestic Swap Counterparties; and (2) Persons Employed in a Clerical or Ministerial Capacity.

Request for Relief Regarding Obligation to Provide Pre-Trade Mid-Market Mark for Certain Foreign Exchange Transactions.

No-Action Relief for Swap Dealers from Certain Swap Data Reporting Requirements of Part 43, Part 45 and Part 46 of the Commission’s Regulations. Due to Effects of Hurricane Sandy.

No-Action Relief from the Commodity Pool Operator Registration Requirement for Commodity Pool Operators of Certain Pooled Investment Vehicles Organized as Business Development Companies

Time-Limited No-Action Relief for Bespoke or Complex Swaps from Certain Swap Data Reporting Requirements of Parts 43 and 45 of the Commission’s Regulations. (Extended by 13-35)

No-Action Letter: Delayed Compliance Date of Amended Part 4; Rescission of Former Appendix A.

No-Action Relief related failure to register with the Commission as a CPO against a CPO that is a Family Office within the meaning and intent of 17 CFR § 275.202(a)(11)(G)-1, as amended.

Time-Limited No-Action Relief from the Clearing Requirement for Swaps Entered Into By Cooperatives.

Time-Limited No-Action Relief from the Clearing Requirement for Swaps Between Affiliated Counterparties.

By letter dated July 16, 2012, X requested that the Division confirm that it will not recommend enforcement action to the Commission concerning X’s proposed repurchase and reverse repurchase transactions (collectively, “repos”) under Commission Regulation 1.25 (investment of customer funds). X intends to enter into repos, using customer funds, subject to Regulation 1.25(d). The repos will subsequently be submitted for clearing by Y, an SEC-registered securities clearing agency. By clearing the repos, Y will become X’s counterparty. Although Y is not a “permitted counterparty” under Regulation 1.25(d)(2), the Division believes that permitting X to clear repos with Y is consistent with the risk-mitigation purpose of the regulation’s counterparty limitations.