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All Letters

Date
All Letters
01/10/2017
17-01 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity from registering as a CPO with respect to several commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.
01/18/2017
17-02 PDF Image; CEA Section 4m(1); No-Action
No-action letter permitting, subject to certain conditions, the CPO of a pool comprised solely of sophisticated institutions that do not invest in the pool for the primary purpose of obtaining an investment return, but rather as part of their respective mandates to promote sustainable economic development to operate said pool without registering as a CPO.
01/26/2017
17-03 PDF Image; Regulation 22.17(b); No-Action
No-action position of DSIO with respect to withdrawals of residual interest related to margin deficits prior to required segregation computation under Commission Regulation 22.17(b).
01/26/2017
17-04 PDF Image; Regulation 4.22; Exemption
Exemptive Relief from the Requirement in Commission Regulation 4.22(c)(7) to Obtain Participant Waivers to provide Unaudited Financial Statements when Liquidating a Series of a Registered Investment Company
02/01/2017
17-05 PDF Image; Section 4s(e) of the Commodity Exchange Act; CFTC Regulations 23.150-170; No-Action
CFTC staff issues time-limited no-action relief from rules on Margin for Uncleared Swaps for Swap Dealers Operating in the European Union
02/06/2017
17-06 PDF Image; § 150.4(c) Aggregation Exemption Notice Filing Requirement; No-Action
Time-Limited No-Action Relief, until 12:01 a.m. eastern standard time on August 14, 2017, from compliance with the notice filing requirements of Commission Regulation 150.4(c), as effective February 14, 2017.
02/01/2017
17-07 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.
02/01/2017
17-08 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.
02/01/2017
17-09 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.
02/01/2017
17-10 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.
02/13/2017
17-11 PDF Image; Section 4s(e) of the Commodity Exchange Act; CFTC Regulation 23.153; No-Action
CFTC Staff issues time-limited no-action relief from March 1, 2017 deadline for compliance with Regulations on Variation Margin for Uncleared Swaps
02/13/2017
17-12 PDF Image; Section 4s(e) of the Commodity Exchange Act; CFTC Regulations 23.152(b)(3) and 23.153(c); No-Action
CFTC Staff issues No-Action relief for Minimum Transfer Amount with respect to Separately Managed Accounts
02/23/2017
17-13 PDF Image; Section 4s(e) of the Commodity Exchange Act; CFTC Regulations 23.153(a) and (b); No-Action
CFTC Staff issues no-action relief to swap dealers for the timing of the posting and collection of variation margin from certain counterparties operating in Japan
02/15/2017
17-14 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.
02/15/2017
17-15 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.
03/10/2017
17-16 PDF Image; Parts 20, 45 and 46 of the Commission’s regulations; No-Action
The CFTC’s Division of Market Oversight further extends time-limited, conditional masking no-action relief provided in CFTC Letters 16-03 and 16-33 permitting Part 45 and Part 46 reporting counterparties to mask legal entity identifiers, other enumerated identifiers and other identifying terms, and permitting Part 20 reporting entities to mask identifying information in certain enumerated jurisdictions, in each case subject to conditions.
03/24/2017
17-17 PDF Image; Commodity Exchange Act section 2(h)(8) and Commission Regulations 37.6(b), 37.1000, 37.1001, 45.2, and 45.3(a); No-Action
The Division of Market Oversight is issuing a no-action letter that extends Letter No. 16-25 and provides relief from: (1) the requirement that a SEF obtain documents that are incorporated by reference in a confirmation issued under Commission Regulation 37.6(b) prior to issuing the confirmation; (2) the requirement that a SEF maintain such documents as records; and (3) the requirement that a SEF report terms contained in such documents that are confirmation data.
03/29/2017
17-18 PDF Image; Regulation 75.14; No-Action
No-Action Relief Regarding the Application of Commission Regulation 75.14(a) to the Provision of Clearing Services by an FCM to a Covered Fund.
04/04/2017
17-19 PDF Image; CEA Section 4m(1); No-Action
The Division of Swap Dealer and Intermediary Oversight (DSIO) granted no-action relief from commodity pool operator (CPO) registration to two entities operating collective investment vehicles to manage the assets belonging to a university, its campuses, affiliated schools, and other supporting organizations, subject to certain conditions outlined in the letter.
03/22/2017
17-20 PDF Image; Regulation 4.7 and 4.22; Exemption
Exemptive relief from the requirement in Commission Regulations 4.7(b)(3) and 4.22(c) to provide an audited Annual Report and Financial Statements when liquidating a commodity pool, if the pool instead provides a combined 13 month Annual Report and Financial Statements.
04/14/2017
17-21 PDF Image; Commission Regulation 39.19(c)(3)(ii); No-Action
Grant of no-action relief for Eurex Clearing AG with regard to Regulation 39.19(c)(3)(ii).
04/18/2017
17-22 PDF Image; Commission Regulations 23.150-23.159; 23.161; No-Action
Extension of time limited no-action position for swap dealers complying with European Union uncleared swap margin requirements.
03/21/2017
17-23 PDF Image; CFTC Regulation 4.7(b)(3); Exemption
Exemptive relief granted to a CPO from filing with NFA and distributing to NFA annual reports for certain subsidiary pools, subject to certain conditions.
04/20/2017
17-24 PDF Image; Regulation 4.33, Regulation 4.7(c)(2); Exemption
Exemptive Relief from the Main Business Office Requirement in Commission Regulations 4.33 and 4.7(c)(2) to allow commodity trading advisors (CTAs) to use Third-party Recordkeepers.
04/28/2017
17-25 PDF Image; CEA Section 5(d)(21) and 5h(f)(13) CFTC Regulations 38.1101(a), 37.1301(a), 38.1101(c), and 37.1303; Other Written Communication
Guidance clarifying the expenses that must be included and those that can be reasonably excluded in a DCM’s or SEF’s calculation of projected operating costs.