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Interpretative Letters

Interpretative Letters
13-27 PDF Image; Rule 1.73(a)(2)(iv); Interpretation
Interpretation of Commission Regulation 1.73(a)(2)(iv).
14-05 PDF Image; Section 5b(c)(2) of the CEA and Part 39 of CFTC Regulations; Interpretation
North American Derivatives Exchange, Inc. (Nadex) requested interpretative guidance concerning certain provisions of the Commission’s Part 39 regulations applicable to derivatives clearing organizations due to the unique nature of Nadex’s business model.
14-40 PDF Image; Regulation 1.16; Interpretation
Interpretation with respect to certain auditor independence requirements under Commission Regulation 1.16.
15-27 PDF Image; Section 2(h)(7)(C)(iii) of the Commodity Exchange Act; Interpretation
The Division of Clearing and Risk published a letter interpreting Section 2(h)(7)(C)(iii) of the Commodity Exchange Act.
14-110 PDF Image; Regulation 30.7; Interpretation
Interpretation of certain aspects of Regulation 30.7.
14-113 PDF Image; CEA Section 1a(10), Regulation 4.10(d); Interpretation
The Division issued an interpretation of CEA Section 1a(10) and Regulation 4.10(d), both of which define the term “commodity pool,” which will permit wholly owned subsidiaries of a single life insurance company to contribute their general account assets to a single vehicle formed by them, and will permit the vehicle to invest directly or indirectly in commodity interests without being deemed a commodity pool.
14-129 PDF Image; Commission Regulations 1.17, 1.22, 22.2, and 30.7; Interpretation
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.
14-132 PDF Image; Regulations 23.701 and 23.704; Interpretation
Staff interpretation regarding notification of the right to segregation of initial margin in uncleared swap transactions and quarterly reporting under Commission Regulations 23.701 and 23.704
14-138 PDF Image; Regulation 30.7; No-Action; Interpretation
No-action relief and interpretation of certain aspects of Regulation 30.7 with respect to the holding of customer funds in accounts located outside of the U.S.

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