No-action positions for commodity pool operators in response to the COVID-19 pandemic

DMO will not recommend that the Commission take an enforcement action against any SEF or SEF CCO for failure to submit an ACR within the 60-day period prescribed in Commission regulation 37.1501(f)(2), provided that: (a) the ACR was required to be submitted to the Commission prior to September 1, 2020, pursuant to Commission regulation 37.1501(f)(2); and (b) the ACR is submitted to the Commission not later than 120 days after the end of the SEF’s fiscal year.

Granting time-limited no-action relief to [“A”] permitting its Irish bank subsidiary, [“B”], to act as reporting counterparty for [“B”]’s swaps with U.S. persons that are not swap dealers (“SDs”) or major swap participants (“MSPs”), notwithstanding the allocation of reporting responsibility set forth in Commission Regulation 45.8(e).

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

DSIO denied a CPO’s request for exemptive relief from the audited annual report requirement for its pools because Division staff concluded that avoiding the audit could be disadvantageous for participants. 

No-Action Extension of no-action relief originally granted by DMO on December 19, 2016 to counterparties clearing swaps through derivatives clearing organizations acting under exemptive or no-action relief from certain reporting obligations for cleared swaps under Part 45 of the Commissions regulations.

Conditional time-limited no-action relief from filing certain Ownership and Control Reports (OCR) required by Parts 17, 18 and 20 of the Commission’s Regulations.

Exemption from specified Part 39 regulations applicable to derivatives clearing organizations due to LedgerX’s fully-collateralized clearing model.

Relief from swap reporting and recordkeeping requirements applicable to Cantor Futures Exchange, L.P. (CX), Cantor Clearinghouse, L.P. and CX’s market participants

Relief from swap reporting and recordkeeping requirements applicable to North American Derivatives Exchange, Inc. (Nadex) and Nadex’s market participants