CFTC Staff Letters Archive

CFTC Staff Letters Archive provides Letters from 2007 and earlier. For Letters published 2008 or later visit the All Letters page.

There are no Advisory Letters or Other Written Communications for 2007 or earlier.

Date PDF and Description
93-97 PDF Image; Section 4m(1);; No-Action
The Division of Trading and Markets granted CPO registration no-action relief to offshore company operating offshore pools, where the company planned periodically to use U.S. CTAs. (T&M)
93-105 PDF Image; Regulation 4.21;; No-Action
The Division of Trading and Markets provided relief to a person registered as a CPO and CTA from disclosing the past performance of two of its principals, where the principals had no prior ownership of the CPO/CTA and had not been involved in its trading decisions. (T&M)
93-96 PDF Image; Section 4m(1);; No-Action
The Division of Trading and Markets granted CPO registration no-action relief to two associated persons, where the APs were the sole shareholders of the registered CPO and where the APs agreed to joint and several liability and to limitations on their activities with respect to the pool. (T&M)
93-91 PDF Image; Section 4m(1);; No-Action
The Division of Trading and Markets granted CPO and CTA registration no-action relief to a registered investment adviser of a group trust comprised of multiple qualified pension and profit sharing plans. (T&M)
93-89 PDF Image; Regulations 4.21, 4.22 and 4.23;; No-Action
The Division of Trading and Markets provided a CPO and CTA with disclosure relief, where the pool at issue consisted of high net worth participants and the pool would commit no more than three percent of its assets to commodity interest trading. (T&M)
93-84 PDF Image; Regulation 4.31;; No-Action
The Division of Trading and Markets provided a CTA relief from disclosing the past performance of trading strategies the CTA tested prior to marketing them to the public when using proprietary funds. (T&M)
93-93 PDF Image; Section 4m(1);; No-Action
The Division of Trading and Markets granted CPO registration no-action relief relief where the pool would use no more than ten percent of its assets to establish its commodity interest trading positions and each participant?s financial resources exceeded what was required to meet the QEP definition. (T&M)
93-87 PDF Image; Section 4m(1);; No-Action
The Division of Trading and Markets granted CPO and CTA registration no-action relief, where the pool would have only three participants who were longstanding friends and accredited investors. (T&M)
93-83 PDF Image; Section 4d;; No-Action
The Division of Trading and Markets granted no-action relief to the CME and CBOT with respect to any CME or CBOT (collectively, Exchange) member firm, its foreign affiliate or Designated Persons of such affiliate in connection with the solicitation, acceptance or entry of orders for existing customers of the Exchange member firm for transactions in Exchange contracts on Globex through a foreign affiliate acting as agent of such Exchange member firm outside normal U.S. business hours (Passing the Book).
93-78 PDF Image; Regulations 1.55 and 1.57;; No-Action
The Division of Trading and Markets granted an IB relief from providing a risk disclosure statement to its clients, where those clients were institutional clients. The IB also was permitted to place futures trades through certain floor brokers, who then gave those trades up to the FCM on behalf of the institutional client. (T&M)