CFTC Staff Letters

CFTC Staff Letters provides Letters from 2008 and later. For Letters published before 2008 visit the Letters Archive page.

Title Body
PDF Image19-17 Letter Type: No-Action, Advisories
Division: DCR, DSIO
Regulation Parts: 1.56, 39.13
Tags: Initial margin, DCO, Disclosures, FCM, Margin, Guarantees Against Loss, Margin Withdrawals
Issuance Date:
Description:

Advisory to FCMs and time-limited no-action relief to DCOs with respect to the treatment of separate accounts by FCMs.

PDF Image19-16 Letter Type: Advisories
Division: DSIO
Regulation Parts: 23.154, 23.157, 23.158, 23.504, 23.600
Tags: Initial margin, Uncleared Swaps, Threshold
Issuance Date:
Description:

Advisory clarifying that no documentation concerning the collection, posting and custody of initial margin is required to be completed until the initial margin threshold amount of $50 million has been exceeded.

PDF Image19-15 Letter Type: No-Action
Division: DCR
Regulation Parts: 39.11, 39.12, 39.13, 39.15, 39.19, 39.21
Tags: Eligibility, Financial Resources, Public Information, Reporting, Risk
Issuance Date:
Description:

No-action relief from specified Part 39 regulations applicable to derivatives clearing organizations due to Eris Clearing, LLC’s fully-collateralized clearing model.

PDF Image19-14 Letter Type: No-Action
Division: DSIO
Regulation Parts: 1.3
Tags: Floor Trader
Issuance Date:
Description:

No-Action relief granted to registered floor traders from compliance with certain conditions in paragraph (6)(iv) of the "swap dealer" definition in CFTC regulation 1.3.

PDF Image19-13 Letter Type: No-Action
Division: DSIO
Regulation Parts: 23.150, 23.151, 23.152, 23.153, 23.154, 23.155, 23.156, 23.157, 23.158, 23.159, 23.160, 23.161
Tags: Initial margin, Margin, Swap Dealer, Swaps, Variation margin, Uncleared Swaps
Issuance Date:
Description:

No-action relief granted to swap dealers from the uncleared swap margin requirements under Part 23 of the Commission's regulations with respect to certain amendments to legacy swaps.

PDF Image19-12 Letter Type: No-Action
Division: DSIO
Regulation Parts: 4m(1)
Tags: CPO, Registration
Issuance Date:
Description:

No-action relief granted to a general partner of a SPE from CPO registration under CEA section 4m(1).

PDF Image19-11 Letter Type: No-Action
Division: DSIO
Regulation Parts: 4m(1)
Tags: Commodity Pool, CPO, Registration, Delegation
Issuance Date:
Description:

No-action relief was granted to an entity from the requirement to register as a CPO with respect to a commodity pool; provided that, the entity delegates its CPO responsibilities for that pool to a registered CPO, subject to certain conditions.

PDF Image19-10 Letter Type: No-Action
Division: DSIO
Regulation Parts: 4d
Tags: IB, Registration
Issuance Date:
Description:

No-action relief granted to an entity for its branch from registration as an IB pursuant to CEA Section 4d(g) to provide sufficient time for the Commission to review the entity’s 30.10 Petition, subject to certain conditions.

PDF Image19-09 Letter Type: No-Action
Division: DMO, DCR, DSIO
Regulation Parts: 2(h)(8), 4d, 4m, 23 Subpart I, 23.502, 45, 46, 50.52
Tags: Brexit
Issuance Date:
Description:

This staff letter ensures that existing regulatory relief provided by DSIO, DMO, and DCR pursuant to certain existing staff letters affecting EU entities continues to be available for UK entities following Brexit.

PDF Image19-08 Letter Type: No-Action
Division: DMO, DSIO
Regulation Parts: 2(h)(8), 5h(a)(1), 23 Subpart F, 23 Subpart I, 23 Subpart J, 37.3
Tags: Brexit
Issuance Date:
Description:

No-action relief granted to ensure the continued availability, following Brexit, of regulatory relief under certain existing CFTC comparability determinations and exemption orders originally issued by the CFTC for EU entities, while CFTC staff undertakes an analysis of UK law in order to make appropriate recommendations of comparability or exemption to the CFTC.