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
94-18 PDF Image; Regulation 4.7;; No-Action
The Division of Trading and Markets permitted a CPO to treat certain non-QEPs as QEPs, where the non-QEPs had significant investment experience and had held senior executive positions with the CPO?s principal. (T&M)
94-16 PDF Image; Regulation 4.7;; No-Action
The Division of Trading and Markets permitted a CPO to treat a non-QEP trust as a QEP, where the trust was irrevocable and was an estate planning vehicle for a family with a net worth in excess of $85 million. (T&M)
94-13 PDF Image; Regulation 4.7;; No-Action
The Division of Trading and Markets permitted a CPO to treat a non-QEP trust as a QEP, where the trustee and sole beneficiary of the trust was itself a QEP. (T&M)
94-07 PDF Image; Section 4m(1);; No-Action
The Division of Trading and Markets granted CPO registration no-action relief to two general partners of a commodity pool, where the general partners were registered as associated persons and listed as principals of a third general partner, who would register as a CPO. (T&M)
94-04 PDF Image; Regulation 4.7;; No-Action
The Division of Trading and Markets permitted a CPO to treat a non-QEP as a QEP, where the non-QEP was an accredited investor with over twenty years? experience as a corporate executive. (T&M)
94-01 PDF Image; Regulation 4.7;; No-Action
The Division of Trading and Markets permitted a CPO to treat a non-QEP as a QEP, where the non-QEP was a corporate and securities law specialist with over twenty years? experience. (T&M)
94-17 PDF Image; Regulation 4.7;; No-Action
The Division of Trading and Markets permitted a CPO to treat certain non-QEPs as QEPs, where the non-QEPs were registered floor brokers who had been active as such for at least the past two years and who would be trading the pool?s assets. (T&M)
94-11 PDF Image; Regulations 4.21, 4.22 and 4.23;; No-Action
The Division of Trading and Markets provided Part 4 relief to a CPO which was a wholly-owned subsidiary of a company that was offering participation in commodity pools to its high-level employees. (T&M)
94-15 PDF Image; Regulation 4.7;; No-Action
The Division of Trading and Markets permitted a CPO to invest more than 10 percent of its pool?s assets in an exempt pool, where non-QEPs invested in the pool before Regulation 4.7 was proposed and the non-QEPs either had a substantial investment portfolio or were involved with the operation of the pool. (T&M)
93-112 PDF Image; Regulation 3.34;; No-Action
The Division of Trading and Markets provided limited relief to certain APs living abroad with respect to the timeframe for compliance with the Commission?s initial ethics training requirement. (T&M)