Staff no-action position regarding the treatment of a deferred tax liability caused by a change in accounting principles.

The Division of Swap Dealer and Intermediary Oversight took a no-action position with respect to IBs guaranteed by a certain FCM, where the IBs would introduce ECP swap counterparties to each other, without opening or carrying customer accounts with the guarantor FCM. For uncleared swaps, no FCM would be involved in the transaction, and for cleared swaps, each counterparty would use an FCM for clearing that the counterparty had selected.

No-Action Relief from Introducing Broker and Commodity Trading Advisor registration for persons located outside the United States in connection with certain activities for customers that are International Financial Institutions.

Request for No-Action Relief for Introducing Brokers’ Compliance with Certain Financial Reporting and Capital Computation Requirements under Regulations 1.10 and 1.17.

The Division of Clearing and Risk issued a letter stating that it will not recommend that the Commission take enforcement action against Singapore Exchange Derivatives Clearing Limited (SGX-DC) clearing members for failing to comply with the Commodity Exchange Act Section 4d(f)(1) registration requirements in carrying existing positions and accepting for clearing offsetting positions in certain commodity swaps for U.S.

The Division of Swap Dealer and Intermediary Oversight issued a “no-action” position from compliance with certain requirements of Regulation 1.57(a)(1), such that a guaranteed introducing broker could open and carry customer accounts with other than its guaranteeing futures commission merchant. Among other things, customers would be eligible contract participants and it was anticipated that the ultimate owner of the guaranteeing futures commission merchant would be the ultimate owner of an interest in the guaranteed introducing broker.

Staff issued an interpretation providing that a futures commission merchant (FCM) may credit a customer’s trading account for a margin payment upon the FCM’s initiation of a withdrawal from the customer’s bank account using the Automated Clearing House (ACH) payment processing system. The FCM also may consider such pending margin payments in computing its regulatory capital.

No-action relief for certain Introducing Brokers from filing certified and unaudited financial statements and calculating capital under regulation 1.17.

The Division of Clearing and Risk issued a letter stating that it will not recommend that the Commission take enforcement action against Singapore Exchange Derivatives Clearing Limited (SGX-DC) clearing members for failing to comply with the Commodity Exchange Act Section 4d(f)(1) registration requirements in carrying existing positions and accepting for clearing offsetting positions in certain commodity swaps for U.S. customers; or SGX-DC for engaging in activities related to its clearing members carrying and accepting for clearing such positions for U.S. customers.

Relief for Additional Agent Affiliates from Registration as an Introducing Broker under Section 4d or a Commodity Trading Advisor under Section 4m of the Commodity Exchange Act.