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
03/20/2000	00-42 ; Investment of FCM Assets: Commodity Futures Trading Commission Regulation 1.17;; No-Action Net capital treatment of an investment in a money market mutual fund operated by an affiliate.
03/16/2000	00-40 ; 4.22(c) & (d);; No-Action The CPO of a small pool which commenced trading September 6, 1999, requested exemption from the requirement of Rule 4.22(d) that the pool's 1999 Annual Report be audited. The participants supported the request. That exemption was granted upon condition that (1) an unaudited 1999 Annual Report be provided to the participants, and (2) the audited 2000 report will include the 1999 data.
03/15/2000	00-39 ; 4.22(c) & (d);; No-Action The CPO of a small pool requested exemptive relieve from the requirement of Rule 4.22(c). There are only two participants in the pool, and the pool ceased trading on February 15, 2000. The participants requested that a fifteen-month audit as of the end of March be granted because a certified Annual Report for such a small pool would result in significant expense to the members. The participants submitted consent waiver statements in support of the exemption.
03/14/2000	00-41 ; Section 5 and 5a of the Act;; No-Action The Division of Trading and Markets (Division) issued a letter to LIFFE Administration and Management (LIFFE) extending the no-action relief that it granted LIFFE by letter dated July 23, 1999, (July 23 Letter) to the FTSE International ? Stars Index (FTSE ? Stars Index) futures contract. The relief is subject to compliance with the terms and conditions of the July 23 Letter and will not become effective until LIFFE receives a no-action position from the Office of General Counsel that permits the offer and sale of a foreign futures contract on the FTSE ? Stars Index in the U.S.
03/10/2000	00-33 ; Regulation 4.7(a);; No-Action The Division of Trading and Markets provided an exemption to a registered CPO from the requirements of Rule 4.7(a) to permit certain employees who are not QEPs, but who are "knowledgeable employees" and defined in Rule 3c-5 of the Investment Company Act of 1940, to invest in a pool operated by the CPO pursuant to Rule 4.7(a).
03/10/2000	00-28 ; Rule 4.7(a);; No-Action The Division of Trading and Markets provided exemptive relief to a registered CPO from the requirements of Rule 4.7(a), to permit an employee who was not a qualified eligible participant (QEP), to invest in a commodity pool operated by the CPO pursuant to Rule 4.7(a), where the employee was a "knowledgeable employee" as defined in Rule 3c-5 of the Investment Company Act of 1940 (17 C.F.R. ? 270.3-5 (1999)), and was the son of the president of the CPO and co-founder of the Fund.
03/10/2000	00-27 ; Section 2(a);; No-Action No-Action letter allowing the London International Financial Futures and Options Exchange futures contract based on the FTSE International Limited Eurotop 100 Index to be offered or sold in the United States.
03/09/2000	00-37 ; 4.22(c) & (d);; No-Action The CPO of a pool, in which all of the participants in the pool were immediate family members of the CPO, requested exemption from filing a certified 1999 Annual Report. The participants submitted consent waiver statements in support of the exemption. The exemption was granted upon condition that (1) an unaudited 1999 Annual Report be provided to the participants, and (2) an unaudited 1999 Annual Report be provided to the Commission and the National Futures Association.
03/08/2000	00-35 ; Rule 4.7(a)(2)(iii);; No-Action "Funds of funds" sought relief from the time requirements of Rule 4.7(a)(2)(iii). Registrant was granted an additional 45 days to distribute to investors and file with the Commission and NFA its Annual Report.
03/07/2000	00-34 ; 4.22(c) & (d);; No-Action The CPO of a small pool which commenced trading October 1, 1999, requested exemption from the requirement of Rule 4.22(d) that the pool's 1999 Annual Report be audited. That exemption was granted upon condition that (1) an unaudited 1999 Annual Report be provided to the participants, and (2) the audited 2000 report will include 1999 data.