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Interpretative Letters

Interpretative Letters
17-51 PDF Image; CEA Section 5b(c)(2)(E) and Commission Regulation 39.14; Interpretation
Interpretation of the Commodity Exchange Act and Commission regulations regarding the characterization of variation margin payments and all other cash flows for cleared swaps.
17-65 PDF Image; CEA Sections 1a(12) and 4m(1), Commission regulations 4.6(a)(3) and 4.14(a)(6); Interpretation
A futures commission merchant (FCM), swap dealer (SD), or introducing broker (IB) that receives separate compensation for commodity trading advice is not required to register as a commodity trading advisor, provided that the offered advice is “solely incidental” to the conduct of the FCM’s or SD’s business, or “solely in connection with” the operation of the IB’s business.
17-68 PDF Image; CEA 1a(10), Commission Regulation 4.10(d); Interpretation
Interpretative relief from the definition of “commodity pool” for certain real estate holding companies.