November 30, 2012

CFTC’s Division of Swap Dealer and Intermediary Oversight Issues Time Limited No-Action Letters for Operators of Certain Funds of Funds

Washington, DC – The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued time limited no-action relief to the operators of funds of funds. The letter provides that DSIO will not recommend that the CFTC take enforcement action against the commodity pool operator of a fund of funds for failure to register as such until the later of June 30, 2013, or six months after the effective date (or compliance date, if later) of any revised guidance that DSIO issues on the application of the de minimis thresholds to funds of funds in the context of CFTC regulations 4.5 and 4.13(a)(3), provided that the commodity pool operator files a claim for no-action relief and that claim meets certain criteria specified in the letter.

Last Updated: November 30, 2012