CFTC Staff Letters

Clarification of Division of Market Oversight No-Action Letter 12-04 (July 17, 2012), and Extension of No-Action Relief for Non-Clearing Member Swap Dealers from Large Swap Trader Reporting Requirements of Section 20.4 of the Commission’s Regulations.

The Division of Market Oversight issued time-limited, no-action relief from the post-allocation swap timing requirement of section 45.3(e)(ii)(A) of the Commission’s regulations.

No-Action Relief: Alternative to Fingerprinting to Establish Fitness of Principals Residing Outside the United States.

Staff No-Action Relief: Preservation of the Regulatory Status Quo Established with Respect to Certain Transactions by the Commission’s Second Amendment to July 14, 2011 Order for Swap Regulation.

Request for Time-Limited No-Action Relief for Certain Futures Commission Merchants from Compliance with Certain Requirements of Commission Regulation 3.3 Relating to Annual Reports by Chief Compliance Officers.

Time-limited no-action relief for Part 20 Reporting Entities regarding identifying information and for Part 45 and Part 46 Reporting Counterparties regarding legal entity identifiers and other identifying information.

The Division of Swap Dealer and Intermediary Oversight issued a letter providing additional guidance to securitization vehicles regarding whether they may be excluded from the definition of commodity pool. The Division also stated that it will not recommend that the Commission take enforcement action against the commodity pool operators of securitization vehicles that have not and will not issue new securities on or after October 12, 2012. Finally, the Division stated that, for securitization vehicles that could not claim relief either under this letter or the 12-14 Letter, it would not recommend enforcement action against operators of securitization vehicles for failure to register as a commodity pool operator until March 31, 2013.

No-Action Relief from the Commodity Pool Operator Registration Requirement for Commodity Pool Operators of Certain Pooled Investment Vehicles Organized as Mortgage Real Estate Investment Trusts.

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.