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All Letters

Date
All Letters
01/07/2000
00-07 PDF Image; Rule 4.13(a)(2) and Rule 4.22(d); Exemption
Withdrawal from registration as a CPO granted under Rule 413(a)(2), and exemption from the certified financial statement requirements of Rule 4.22(d).
01/12/2000
00-08 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets provided an exemption to a registered commodity pool operator (CPO) from the requirements of Rule 4.7(a) to permit certain employees who are not qualified eligible participants (QEPs), but who are "knowledgeable employees" as defined in Rule 3c-5 of the Investment Company Act of 1940 (17 C.F.R. ?270.3c-5 (1999)) to invest in a commodity pool operated by the CPO pursuant to Rule 4.7(a).
01/06/2000
00-10 PDF Image; Section 4m(1) -- No Action Position from CPO Registration; No-Action
The Division of Trading and Markets provided a no-action position to a University's cooperative extension service, its agents and employees permitting them to offer seminar courses to certain students who have completed a specific undergraduate course sequence that would allow those students to trade commodity interests through participation in a Trading Club.
01/28/2000
00-11 PDF Image; 4.22(c) & (d); Exemption
The CPO of a small pool dissolved the end of November and requested exemption from the requirement of Rule 4.22(d) that the pool's 1999 Annual Report be audited. The participants submitted consent waiver statements in support of the exemption. The exemption was granted upon condition that an unaudited 1999 Annual Report be provided to the participants.
01/31/2000
00-12 PDF Image; Rule 4.22(c) & (d); Exemption
The CPO of a small pool which has never traded futures or options and requested exemption from the requirement of Rule 4.22(d) that the pool's 1999 Annual Report be audited. The participants submitted consent waiver statements in support of the exemption. The exemption was granted upon condition that an unaudited 1999 Annual Report be provided to the participants.
02/01/2000
00-13 PDF Image; Rule 4.22(c) & (d); Exemption
The CPO of a small pool which commenced trading July 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.
01/28/2000
00-14 PDF Image; Regulation 4.7(b); Exemption
The Division of Trading and Markets provided an exemption to a registered CTA, permitting it to treat a pool as a QEC for the purposes of its advising the pool pursuant to Rule 4.7(b), where each of the current limited partners of the pool is a principal of either the CTA or the CPO. The letter also denied the CTA relief from the QEC criteria of Rule 4.7(b) with respect to additional limited partners of the pool where the CTA did not present any special facts or circumstances that would permit it to treat such limited partners as QECs.
01/28/2000
00-15 PDF Image; Rule 4.33; Exemption
The Division of Trading and Markets provided exemptive relief to a registered CTA from the requirements of Rule 4.33 that the firm must maintain its books and records at its main business office, so that it could keep certain books and records at the futures commission merchant where all accounts managed by the CTA will be carried.
01/28/2000
00-16 PDF Image; Regulation 4.7(a); Exemption
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" as defined in Rule 3c-5 of the Investment Company Act of 1940, to invest in certain commodity pools operated by the CPO pursuant to Rule 4.7(a).
01/28/2000
00-17 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets provided exemptive relief to two registered CPOs that permits the CPOs to treat their non-QEP employees as QEPs for purposes of the employees' investments in funds operated by the CPOs pursuant to Rule 4.7(a) because the employees are either "knowledgeable employees" as that term is defined in Rule 3c-5 under the Investment Company Act of 1940 or have been employed in the financial services industry for at least two years and are "accredited investors" as that term is defined in Rule 501(a)(6) under the Securities Act of 1933.
02/24/2000
00-18 PDF Image; 4.22(c) & (d); Exemption
The CPO of a small pool which started in late 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. The 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.
02/18/2000
00-19 PDF Image; Rule 4.33; Exemption
An offshore CTA entered into an agreement with a U.S. CPO to maintain the books and records of the CTA's client. The CTA and CPO both filed 4.7 notices and the CTA will not solicit any other client business. The exemption was granted upon condition that (1) the CTA notify the Division if the location of any such books and records changes from that as represented to us; and (2) CTA remains responsible for the maintenance of all required books and records.
02/16/2000
00-20 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets provided exemptive relief to a registered CPO that permits the CPO to treat a non-QEP employee as a QEP for purposes of the employee's investment in funds operated by the CPO pursuant to Rule 4.7(a) because the employee is a "knowledgeable employee" as that term is defined in Rule 3c-5 under the Investment Company Act of 1940.
02/29/2000
00-21 PDF Image; Section 2(a); No-Action
No-Action letter allowing the MONEP Exchange's futures contracts based on the Dow Jones STOXX 50 Index and the Dow Jones EURO STOXX 50 Index to be offered or sold in the United States.
03/03/2000
00-23 PDF Image; Rule 4.22(c) & (d); Exemption
The CPO of a pool undergoing an orderly closing and liquidation of assets by the end of January 2000 requested exemption from the requirements of Rule 4.22(d) that the pool's 1999 Annual Report be audited. The participants submitted consent waiver statements in support of the exemption. The exemption was granted upon condition that an unaudited 1999 Annual Report be provided to the participants.
02/11/2000
00-24 PDF Image; 4.22(c) & (d); Exemption
The CPO of a small pool requested exemptive relief from the requirement of Rule 4.22(d) because the cost of a certified audit would be excessively expensive relative to the fund's assets. The participants submitted consent waiver statements in support of the exemption. The exemption was granted upon condition that an unaudited 1999 Annual Report be provided to the participants.
02/29/2000
00-25 PDF Image; 4.22(c) & (d); Exemption
The CPO of a small pool requested exemptive relief from the requirement of Rule 4.22(d) whose only two investors in the pool are the sole principal of the CPO and his spouse. The participants submitted consent waiver statements in support of the exemption. The exemption was granted upon condition that an unaudited 1999 Annual Report be provided to the participants.
03/02/2000
00-26 PDF Image; 4.22(c) & (d); Exemption
The CPO of a small pool which started in late 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. The exemption was granted upon condition at (1) an unaudited 1999 Annual Report be provided to the participants, and (2) the audited 2000 report will include 1999 data.
03/10/2000
00-27 PDF Image; 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.
03/10/2000
00-28 PDF Image; Rule 4.7(a); Exemption
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.
02/23/2000
00-30 PDF Image; Rule 1.46; No-Action
The Division of Trading and Markets provided no-action relief to registered FCMs carrying the accounts of members of the Chicago Mercantile Exchange participating in "market marker" programs sponsored by the Exchange for particular contract markets. To administer the programs, the Exchange will require participants to maintain separate accounts for market-making and regular trades, in which positions might be held that would otherwise be required to be offset by operation of Commission Rule 1.46.
02/29/2000
00-32 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets provided exemptive relief to a registered CPO that permits the CPO to treat four non-QEP investors as if they satisfy the criteria of Rule 4.7(a). The investors are managing directors of the CPO and have been employed by the CPO for over six years. As such, it appears that they are "knowledgeable employees" as that term is defined in Rule 3c-5 under the Investment Company Act of 1940.
03/10/2000
00-33 PDF Image; Regulation 4.7(a); Exemption
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).
03/07/2000
00-34 PDF Image; 4.22(c) & (d); Exemption
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.
03/08/2000
00-35 PDF Image; Rule 4.7(a)(2)(iii); Exemption
"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.
03/06/2000
00-36 PDF Image; 4.22(c) & (d); Exemption
The CPO of a small pool requested exemption from the requirement of Rule 4.22(d) that the pool's 1999 Annual Report be audited. The participants supported the request. The exemption was granted upon condition that an unaudited 1999 Annual Report be provided to the participants.
03/09/2000
00-37 PDF Image; 4.22(c) & (d); Exemption
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.
03/15/2000
00-39 PDF Image; 4.22(c) & (d); Exemption
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.
03/16/2000
00-40 PDF Image; 4.22(c) & (d); Exemption
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.
03/14/2000
00-41 PDF Image; 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.
03/20/2000
00-42 PDF Image; Investment of FCM Assets: Commodity Futures Trading Commission Regulation 1.17; Interpretation
Net capital treatment of an investment in a money market mutual fund operated by an affiliate.
03/31/2000
00-44 PDF Image; Section 4d(1); No-Action
The Division of Trading and Markets (Division) issued an IB registration no-action position to a United States bank whose foreign branches wish to refer foreign customers to a registered FCM. The Division's position was based upon the bank's representations, among others, that: (1) the bank is a national banking association regulated by the OCC; (2) the bank's offices in the United States will not engage in any activities subject to regulation by the Commission; (3) the bank will identify to the Commission the foreign branches that will engage in the above-described conduct; (4) the registered FCM will be jointly and severally liable with the bank for any violations of the CEA or regulations issued thereunder arising from or relating to the foreign branches' referral activities; (5) the foreign branches will do no more than refer foreign customers who want to enter into futures transactions on United States markets to the FCM, and the FCM will be responsible for the transactions; and (6) the foreign branches are subject to regulation by the relevant regulatory authorities in the countries in which they are located.
03/31/2000
00-45 PDF Image; 4.21, 4.22, 4.23(a)(10) and (a)(11); Exemption
The CPO of a small pool requested exemptive relieve from the above requirements in connection with the operation of an offshore commodity pool. The request met the requirements of Commission Advisory 18-96, and the exemption was granted upon condition that the CPO agree to certain conditions.
03/31/2000
00-46 PDF Image; Regulation 4.7; Exemption
A registered CPO requested relief from the requirement of filing an annual report in accordance with Section 4.7(a)(iii)(A). The CPO only filed a balance sheet for the end of the year. The request for relief was denied.
04/03/2000
00-47 PDF Image; 4.22(a) and (c); Exemption
The CPO of two separate pools requested relief from filing separate financial information for both. Based on the ownership structure, one pool invests substantially all of its assets in the other. The relief granted is subject to the CPO filing and distributing annual reports and periodic account statements representing the combined activities of the pools and the administrative participant in the pool submitting acknowledgment that it understands and agrees to the omission of receiving certain financial reporting information.
04/03/2000
00-48 PDF Image; Rule 30.10; Interpretation
The Division of Trading and Markets (Division) confirmed that, for U.S. customers trading the LMEX contract on the London Metal Exchange (LME), LME firms may comply with the standard provision for segregation of customer funds instead of the alternative segregation provision. Under Commission Rule 30.10 the Commission issued orders in May 1989 permitting U.K. firms to solicit and accept orders from U.S. customers for trading on U.K. markets, including LME. Because LME contracts have traditionally not been cash settled, U.K. firms were permitted, in lieu of standard segregation, to maintain a binding letter of credit or bank guarantee to cover forward profits and clearing exposures on the LME (i.e., the alternative segregation provision). The LMEX contract, however, will be cash settled and LME believes that standard segregation is appropriate with respect to that contract. The Division has confirmed that LME firms can treat the LMEX contract under standard segregation and all other LME contracts under the alternative segregation provision, even if the same customer is involved.
03/24/2000
00-49 PDF Image; Section 4m(1); No-Action
The Division of Trading and Markets took a CPO registration "no-action" position with respect to a real estate investment trust that intended to use commodity interest trading solely for bona fide hedging transactions, that would commit no more than 0.5% of the fair market value of its assets to commodity interest trading, and that would limit income derived from commodity interest trading to 5% of its gross income. The Division also took a CTA registration no-action position with respect to the closely-affiliated advisory entity, on the condition that it does not provide commodity interest trading advice to any other person.
03/24/2000
00-50 PDF Image; Section 4m(1); No-Action
The Division of Trading and Markets took a CPO registration "no-action" position with respect to a real estate investment trust that intended to use commodity interest trading solely for bona fide hedging transactions, that would commit no more than 1% of the fair market value of its assets to commodity interest trading, and that would limit income derived from commodity interest trading to 5% of its gross income. The Division also took a CTA registration no-action position with respect to the closely-affiliated advisory entity, on the condition that it does not provide commodity interest trading advice to any other person.
04/06/2000
00-51 PDF Image; Section 2(a); No-Action
No-Action request to permit the offer and sale in the U.S. of futures contracts on the Morgan Stanley Capital International Incorporated Pan-Euro Index and the Morgan Stanley Capital International Incorporated Euro Index traded on the London International Financial Futures and Options Exchange.
04/06/2000
00-52 PDF Image; Section 2(a); No-Action
No-Action request to permit the offer and sale in the U.S. of futures contracts on the Dow Jones STOXX 50 Index and the Dow Jones EURO STOXX 50 Index traded on the Eurex Deutschland.
03/24/2000
00-53 PDF Image; Section 4m(1); No-Action
The Division of Trading and Markets took a CPO registration "no-action" position with respect to the directors of a real estate investment trust (REIT) formed to invest primarily in single-family non-conforming mortgage securities and loans. This position was based upon representations, among others, that the REIT: intended to use commodity interest trading solely for bona fide hedging transactions; would commit no more than 1% of the fair market value of its assets to commodity interest trading; and would limit income derived from commodity interest trading to 5% of its gross income. The Division also took a CTA registration no-action position with respect to the two executives of the REIT who will provide it commodity interest trading advice, on the condition that the executives do not provide such trading advice to any other person.
03/30/2000
00-54 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets permitted a registered CPO to continue to treat a pool established for the employees of the manager of a fund as if it satisfies the QEP criteria of Rule 4.7(a) in connection with the investment of the pool in the fund, notwithstanding the addition of two non-QEP employees to the pool. The non-QEP employees are: (1) employed by the manager of the fund as research analysts; (2) have over two years experience in the financial services industry; and (3) are accredited investors as defined in Rule 501(a)(6) under the Securities Act of 1933. The Division also permitted the CPO to maintain its exemption from the specific requirements of Rules 4.21 through 4.26 in connection with its operation of the employee pool.
04/05/2000
00-55 PDF Image; Section 2(a); No-Action
No-Action letter allowing the London International Financial Futures and Options Exchange futures contracts based on the FTSE International Limited Eurobloc 100 Index, the FTSE International Limited Eurotop 300 Index, and the FTSE International Limited Eurotop 300 (Ex. U.K.) Index to be offered or sold in the United States.
04/13/2000
00-56 PDF Image; 1996-1998 Transfer Binder; Interpretation
This letter revises a Commission letter dated December 4, 1997, and advises the National Futures Association (NFA) to cease using CFTC Rule 1.63 as the basis for evaluating the impact of a floor broker's (FB) or floor trader's (FT) exchange disciplinary history on his or her fitness to be registered pursuant to the "other good cause" provision of Section 8a(3)(M) of the Commodity Exchange Act (Act). Instead, NFA should rely on the standard enunciated in In the Matter of Clark
02/29/2000
00-57 PDF Image; Rule 4.13(a)(1), Rule 4.13(b)(2)(I)(A) and (B), and Rule 4.7(a)(1)(ii)(B)(2)(xi); Interpretation
The Division of Trading and Markets confirmed availability of CPO registration exemption under Rule 4.13(a) for managing members where LLC was formed as investment vehicle for partners and key employees of a law firm. The Division also granted exemption permitting substitute compliance with reporting requirements for the LLC because it trades through investee vehicles and thus cannot timely obtain necessary information from investee vehicle operators to permit normal compliance. The Division granted exemption permitting the LLC to be treated as a QEP, notwithstanding that not all of its members are QEPs, if the LLC invest more than ten percent of its assets in Rule 4.7 exempt pools.
04/04/2000
00-58 PDF Image; 4.22 (c) & (d); Exemption
The CPO of a small pool which commenced trading December 1, 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. The 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.
05/02/2000
00-59 PDF Image; Section 4d(2) of the Commodity Exchange Act and Commission Regulation 1.32; No-Action
The Division of Trading and Markets took a "no-action" position with respect to a futures commission merchant (FCM) that requested to use customer-owned debt securities issued by The Federal National Mortgage Association (Fannie Mae) or The Federal Home Loan Mortgage Corporation (Freddie Mac) to offset net liquidating deficits in customers' accounts when the FCM computes its segregation requirement under Section 4d(2) of the Commodity Exchange Act and Commission Regulation 1.32.
04/28/2000
00-60 PDF Image; Rule 4.23; 4.33; Exemption
The Division of Trading and Markets provided exemptive relief to a registered CPO and CTA from the requirements of Rules 4.23 and 4.33 that the firm must maintain its books and records at its main business office, so that it could keep certain books and records at an administrative office. The Division granted the relief subject to the conditions: that the firm notify the Division if the location of the books and records changes: that the firm ensure that the books and records are maintained in accordance with the Commission's Rules; that the firm retrieve the books and records within 48 hours to its main business location upon request by the Commission; that the firm must disclose where all the required books and records are kept in its disclosure documents; and that the firm would remain responsible for the provisions of CFTC Rules 4.23 and 4.33
05/12/2000
00-61 PDF Image; Section 4m(1); No-Action
The Division of Trading and Markets granted relief from the commodity trading advisor registration requirement of Section 4m(1) to the investment adviser of the manager of a family of funds based upon, among other things, representations that: (1) the investment adviser is registered with the Securities and Exchange Commission under the Investment Advisers Act of 1940; (2) the funds and the manager of the funds are organized outside of the United States; (3) no United States person will participate directly or indirectly in the funds; and (4) the investment adviser will comply with all applicable requirements of Rule 4.14(a)(8), including the manner in which it provides commodity interest trading advice to the funds.
05/09/2000
00-62 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets provided an exemption to two registered commodity pool operators (CPOs) and commodity trading advisors (CTAs) from the requirements of rule 4.7(a) to permit certain persons, who are not qualified eligible participants (QEPs), but who are related to the principals of one of the co-CPOs, to invest in a commodity pool operated by the co-CPO pursuant to rule 4.7(a).
05/12/2000
00-63 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets granted an exemption to a registered commodity pool operator (CPO) from the requirements of rule 4.7(a) to permit certain employees who are not qualified eligible participants (QEPs) but who are "knowledgeable employees" as defined in rule 3c-5 of the Investment Company Act of 1940 (17 C.F.R. 270.3c-5) to invest in three commodity pools operated by the CPO pursuant to rule 4.7(a).
05/08/2000
00-64 PDF Image; Part 35 of the Commission's rules; No-Action
The Division of Trading and Markets and Economic Analysis provided no-action relief to a proposed electronic trading platform for the trading of physical commodities and derivatives products. The no-action letter notes that the terms and conditions of the letter and the operation of the platform might need to be modified to reflect any applicable rules that the Commission might adopt in this area.
05/16/2000
00-65 PDF Image; Section 4m(1); Other Written Communication
The Division of Trading and Markets declined to take a CPO registration "no-action" position with respect to past acts by two individuals and certain entities operated by them, which acts would ordinarily trigger CPO registration requirements. The Division cited its long-standing practice of refusing to issue no-action or exemptive letters with retroactive application, and it specifically referred to language in the 1998 adopting release for Rule 140.99.
05/09/2000
00-66 PDF Image; Rule 4.7(a)(2)(ii) and (iii) and Rule 4.7, 4.21, and 4.22; Exemption
The Division of Trading and Markets exempted a registered CPO from the reporting requirements of Rule 4.7(a)(2)(ii) and (iii) with respect to certain existing investment funds (sub-funds) operated by the CPO and in which the only participants were other funds (feeder funds) operated by the same CPO. The exemption was conditioned upon (1) exclusion from participation in the sub-funds of any persons other than feeder funds operated by the CPO, and (2) issuance by each feeder fund to its participants of annual audited financial reports that incorporate the performance of the relevant sub-fund(s). Requested prospective relief with respect to similar future sub-funds was denied.
05/26/2000
00-67 PDF Image; Rule 4.7(a) and 4.7(a)(1)(ii)(B)(2)(xi); No-Action
The Division of Trading and Markets confirmed effectiveness of prior no-action positions where a CPO operating investment vehicles for the benefit of its parent company's employees proposed to expand eligibility for participation in those investment vehicles to include employees who were not accredited investors. Confirmation was made subject to compliance with the following conditions and undertakings. Non-accredited investors would be required: (1) to have a combination of graduate or undergraduate degree and relevant professional experience; (2) to have income of $100,000 in most recent year and prospects to receive $140,000 in each subsequent year; and (3) to limit investment to no more than 15% of the investor's income. CPO undertook otherwise to comply with the terms of the prior no-action letters, to cause the investment vehicles to issue audited annual reports and an offering memorandum to participants and to provide the CFTC with a copy of the amended Order to be issued by the Securities and Exchange Commission under Section 6(b) of the Investment Company Act of 1940.
05/22/2000
00-68 PDF Image; Regulation 4.7(a); Exemption
The Division of Trading and Markets granted an exemption to a registered commodity pool operator (CPO) from the requirements of rule 4.7(a) to permit certain employees who are not qualified eligible participants (QEPs) but who are "knowledgeable employees" as defined in rule 3c-5 of the Investment Company Act of 1940 to invest in a commodity pool operated by the CPO.
05/22/2000
00-69 PDF Image; Rule 4.7(a), 4.21, 4.22, 4.23(a)(3), 4.23(a)(10) and 4.23(a)(11); Exemption
The Division of Trading and Markets provided exemptive relief to a registered CPO that permits the CPO to continue to treat an employee partnership as if it satisfies the QEP criteria of Rule 4.7(a) and provided exemptive relief to the registered CPO of the employee partnership from Rules 4.21, 4.22, 4.23(a)(3), 4.23(a)(10) and (a)(11) in connection with his operation of the employee partnership, notwithstanding the addition of two non-QEP investors to the employee partnership, based on the representation that the non-QEP investors were "knowledgeable employees" as that term is defined in Rule 3c-5 under the Investment Company Act of 1940.
05/26/2000
00-70 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets relieved a registered CPO, in connection with its operation of a master fund, from its obligation pursuant to Rule 4.7(a)(2)(ii) to deliver account statements to three feeder funds that were also operated by the CPO, on the conditions that: (1) the CPO remains the CPO of the master fund and the feeder funds, and (2) the CPO continue to comply with the requirements of Rule 4.7(a)(2)(ii) in connection with all other investors in the master fund.
05/26/2000
00-71 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets provided exemptive relief to a registered CPO that permits the CPO to treat an employee of the parent organization of the majority owner and managing member of the CPO as if he satisfies the QEP criteria of Rule 4.7(a). The employee has over two years' experience in the financial services industry and is an accredited investor as that term is defined in Rule 501(a)(5) under the Securities Act of 1933.
05/30/2000
00-72 PDF Image; Rule 4.22; Exemption
The CPO of a small pool requested exemptive relieve from the above requirement in respect to the Annual Reports that Rule 4.22(c) specifies the CPO must distribute to participants and file with the Commission. The exemption was granted upon condition that the CPO distribute an unaudited Annual Report for 1999 and for the period ending upon the permanent cessation of trading that otherwise complies with the Rules 4.22 (c) and (d).
05/25/2000
00-73 PDF Image; Section 2(a); No-Action
No-Action letter allowing the OM Exchange Limited standardized and flexible futures contracts and the OM Stockholm standardized futures contract on the OMXCAP Index to be offered and sold in the United States.
06/08/2000
00-74 PDF Image; 4.22(c) & (d); Exemption
The CPO of a pool undergoing an orderly closing and liquidation of assets by the end of February 2000, requested exemption from the requirement of Rule 4.22(d) that the pool's 2000 Annual Report (to be filed 90 days after cessation on February 29, 2000) be audited. The participants submitted consent waiver statements in support of the exemption. The exemption was granted upon condition that the unaudited monthly reports of January 2000, and February 2000, be provided to the participants.
06/09/2000
00-75 PDF Image; Section 5 and 5a of the Act; No-Action
The Division of Trading and Markets (Division) issued a letter granting no-action relief to permit Hong Kong Futures Exchange Limited (HKFE) to make its electronic trading and order matching system, known as Hong Kong Automated Trading System (HKATS), available to Exchange Participants in the US without obtaining contract market designation pursuant to Sections 5 and 5a of the CEA.
06/13/2000
00-76 PDF Image; Rule 4.22 (c) & (d); Exemption
The CPO of a pool, which ceased operations at the end of November, requested exemption from the requirements of Rules 4.22 (c) and (d) that the pool's 1999 Annual Report be audited. The participants submitted consent waiver statements in support of the exemption. The exemption was granted upon condition that an unaudited 1999 annual report be provided to the participants.
06/21/2000
00-77 PDF Image; Section 2(a); No-Action
No-Action letter allowing the Singapore Exchange Derivatives Trading, Limited futures contract based on the Morgan Stanley Capital International Incorporated Singapore Free Stock Index to be offered or sold in the United States.
06/30/2000
00-78 PDF Image; Foreign Trading System No-Action Letter; Other Written Communication
The Commission issued a Statement of Policy expressing the view that foreign boards of trade that have placed automated trading systems in the U.S. pursuant to a Commission staff no-action letter should be permitted to list additional futures and option contracts through such systems without further regulatory action, subject to certain filing and certification requirements. The Statement of Policy does not apply to contracts that are covered by Section 2(a) (1) (B) of the CEAct.
06/30/2000
00-79 PDF Image; Section 4f(b) of the CEAct and Commission Regulation 1.17(c)(5)(x); No-Action
The Division of Trading and Markets took a "no-action" position with respect to a futures commission merchant (FCM) that, in computing its adjusted net capital, takes less than the full capital charge on open futures positions associated with its market making activities in the Goldman Sachs Commodity Index (GSCI) futures contract. As part of its market making activities, the FCM generally holds a core short position in the GSCI futures contract. The FCM manages the risk associated with the short GSCI position by going long in each of the futures contracts that comprise the GSCI. The no-action letter provides that the Division would not recommend enforcement action to the Commission if, in computing its adjusted net capital, the FCM did not take the full capital charges set forth in Regulation 1.17(c)(5)(x) on the futures contracts hedging the open GSCI futures positions.
06/30/2000
00-80 PDF Image; Part 35 of the Commission's rules; No-Action
On June 30, 2000, the Division of Trading and Markets issued a letter granting no-action relief in connection with the operation of a proposed electronic trading platform for the trading of physical commodities and derivative products relating to crude oil, heating oil, unleaded gasoline and jet kerosene. The platform will utilize an electronic trading and matching system that can be accessed through the Internet or dedicated communication lines, and it will be available only to approved participants and authorized brokers entering orders on their behalf. Participants will be limited to commercial entities that qualifying as "eligible swap participants" under specified provisions of Part 35 of the Commission rules.
07/05/2000
00-81 PDF Image; Rule 4.7(a); Exemption
The Division of Trading and Markets provided exemptive relief to a registered CPO that permits the CPO to treat five non-QEP investors, who are employed as analysts by the manager of the fund operated by the CPO, as if they satisfy the QEP criteria of Rule 4.7(a). The CPO represented that they are "knowledgeable employees" as that term is defined in Rule 3c-5 under the Investment Company Act of 1940.
07/05/2000
00-82 PDF Image; Section 4m(1); No-Action
The Division of Trading and Markets granted relief from the commodity pool operator registration requirement of Section 4m(1) to the co-general partner of a commodity pool partnership based upon, among other things, representations that: (1) the other general partner is registered as a CPO; (2) the other general partner is the president and a ninety percent shareholder of the co-general partner; (3) the other general partner is the managing general partner of the partnership and, as such, will undertake all CPO responsibilities in connection with the partnership, including performing all activities subject to regulation by the Commission; and (4) both general partners acknowledged that they will be jointly and severally liable for any violations of the Act or the Commission's regulations committed by the other in connection with the operation of the partnership.
07/05/2000
00-83 PDF Image; Section 4m; No-Action
The Division of Trading and Markets: (1) confirmed continued effectiveness of previously-taken CTA and CPO registration no-action positions with respect to the operation of, and the providing of commodity interest trading advice to, a group of Puerto Rican investment companies (and similar investment companies yet to be formed), notwithstanding the substitution of an affiliated trust company for one of the two joint managing entities; and (2) took a CPO and CTA registration no-action position with respect to the trust company. The Division replied, in part, upon representation that: (1) 75% or more of the directors of each investment company are Puerto Rico residents; (2) shares will be sold exclusively to persons having principal residences or places of business in Puerto Rico; (3) each investment company will be registered as such under Puerto Rico law; (4) Rule 4.5(c)(2) trading restrictions will be observed; and (5) the trust company will comply with Rule 4.14(a)(8) in advising the investment companies. These positions were conditioned upon submission by the trust company to special calls.
08/09/2000
00-85 PDF Image; Rule 4.7(b) and 4.22; Exemption
The Division of Trading and Markets provided exemptive relief in which a firm would not be required to provide periodic statements and an annual report to the participants in two sub-funds operated by the firm because: (1) the firm limits participation in the sub-funds to itself and the feeder funds it also operates, thereby prohibiting individual investors from participating in the funds; and (2) the firm is the CPO of the sub-funds and the feeder funds. Relief is subject to the conditions that: (1) the firm remains the CPO of the sub-funds and the feeder funds; (2) the firm limits participation in the sub-funds to itself and the feeder funds; and (3) the annual reports of the feeder funds contain financial statements that include, among other required information, the fees associated with the operation of the respective sub-fund.
08/09/2000
00-86 PDF Image; Rules 4.21, 4.22 and 4.23; Exemption
The Division of Trading and Markets exempted a registered CPO from specific disclosure, reporting and recordkeeping requirements where the CPO is the general partner of the holding company for a group of affiliated real estate and restaurant development, operation and management entities, and is also the general partner of the entity holding the group's liquid assets. All investors in the holding company are family members or business associates of the CPO's owner, who is a former commodity options (CBOT member) and who makes all commodity interest trades for the group's liquid assets subsidiary.
09/11/2000
00-87 PDF Image; Regulation 4.21, 4.22; Exemption
The Division of Trading and Markets granted a registered CPO an exemption from the requirements of Rules 4.21 and 4.22 to distribute disclosure documents, periodic account statements, and annual reports, where the CPO is operating a "Master Fund" which limits participation to two "Feeder Funds" that are also operated by the CPO. The exemption was conditioned upon: (1) the CPO remaining the CPO of the Master Fund and Feeder Funds; (2) participation in the Master Fund being limited to the CPO and the Feeder Funds; (3) the CPO disclosing the master-feeder fund structure to current and potential investors in the Feeder Funds; and (4) the annual reports of the Feeder Funds containing financial statements that include the fees associated with the operation of the Master Fund.
09/11/2000
00-88 PDF Image; Regulation 4.7(b); Exemption
The Division of Trading and Markets granted a registered CPO an exemption from Rules 4.7(b)(3) and (b)(4), such that the CPO was granted: (1) an extension of time in which to distribute and file the annual reports of specified pools that invest assets in offshore vehicles; and (2) permission to maintain certain original books and records for these pools at their respective trustee, administrator, or custodian.
09/11/2000
00-89 PDF Image; CEAct ' 4m(1), Regulation 4.10(d)(1); Interpretation
Intrepration that a limited partnership engaged in pork production that trades commodity interests solely to hedge against the price risks associated with that business is not a "pool" within the meaning and intent of Rule 4.10(d)(1), and that consequently, the general partner of the partnership is not a CPO thereof.
08/30/2000
00-90 PDF Image; 4.22(c) and (d); Exemption
The CPO of a fund of fund pool liquidated its assets by the end of 1999. The CPO requested that the Fund be granted relief from filing an annual report and exemption from the requirement of Rule 4.22(d) that the pool's 1999 annual report be audited. The participants submitted consent waiver statements in support of the exemption. The Fund's request not to file an Annual Report was denied; however, the Fund was granted relief from certification upon condition that an unaudited 1999 annual report be provided.
09/13/2000
00-91 PDF Image; Rule 1.46; No-Action
The Division of Trading and Markets took a "no-action" position permitting a registered CPO and CTA to use a combination of separate trading programs to trade the accounts of several commodity pools (including pools that it operated as well as pool's operated by unaffiliated registered CPOs), without requiring the FCMs handling any such pools account(s) to close out offsetting positions generated by operation of the combined trading programs of a particular pool client. The no-action position was taken even though the CPO/CTA did not clearly demonstrate that it separately marketed the trading programs involved, and the Division imposed conditions including, inter alia, maintenance of records of offsetting positions, no participation by the CPO/CTA in round turn brokerage fees generated by offsetting positions, prior written permission from unaffiliated CPOs or trading managers to maintain offsetting positions, and inclusion in CPO Disclosure Documents of a risk factor explaining that offsetting positions may be generated and the potential for incurring extra costs to be borne by the pool.
09/20/2000
00-92 PDF Image; Regulation 4.7(a); Exemption
The Division of Trading and Markets (Division) granted an exemption from the qualified eligible person (QEP) criteria of Rule 4.7 (a) so that a CPO and CTA of a fund could continue to operate the fund as an exempt pool, notwithstanding the participation in the fund of certain of the CPO/CTA's employees who do not meet the QEP criteria. This letter would incorporate other prior no-action letters granted to the CPO/CTA in connection with its operation of the fund, and differs from these prior grants of relief in that the CPO/CTA would now be registered in those capacities with the Commission. In addition, the CPO/CTA agreed to continue to comply with the conditions set forth in the prior grants of relief.
09/21/2000
00-93 PDF Image; Section 5 and 5a of the Act; No-Action
The Division of Trading and Markets (Division) issued a letter granting no-action relief to permit OM London Exchange Limited (OM London) to make its electronic trading and order matching system, known as the OM Click Exchange System (OM Click), and its electronic clearing system, known as OM SECUR Clearing System (OM SECUR), available to exchange participants in the U.S. without obtaining contract market designation pursuant to Sections 5 and 5a of the CEA.
09/27/2000
00-94 PDF Image; Rule 1.57(a)(1) and Rule 30.10; No-Action
The Division of Trading and Markets permitted the New York branch of a French bank to register in the U.S. as an introducing broker, to be guaranteed by a registered U.S. FCM that is subsidiary of the same bank, and to introduce business to the London branch of the same bank. The letter stated that the Division will not recommend enforcement action: (1) against the bank or its New York branch based solely upon their failure to register as FCMs in accordance with Section 4d(1) of the CEAct and Commission Rule 3.10, or (2) against the U.S. FCM or the bank for failure of the New York branch to introduce all customer accounts to the guaranteeing FCM, as required by Rule 1.57(a)(1). This letter was issued in connection with confirmation by the Commission of Rule 30.10 relief for the London branch, which permits it to solicit and accept orders and funds from U.S. customers for trades on boards of trade located outside the U.S. without registration as an FCM. The New York branch was treated essentially as an affiliate or subsidiary rather than a branch so that the Rule 30.10 relief would be available to the London branch.
10/03/2000
00-95 PDF Image; Section 4m(1) of the CEAct and CFTC Rules 4.5 and 4.14(a)(8); No-Action
The Division of Trading and Markets issued a no-action position to an investment company incorporated outside the U.S. to permit it to operate certain commodity pools organized outside the U.S. without registering as a CPO, despite the fact that the company has several U.S. persons serving as directors. This Division took this position because, among other things: 1) no U.S. person will participate in the pools, except that a U.S. affiliate of the foreign investment company and certain management employees will have voting rights for a particular pool and the U.S. affiliate has contributed a small amount of seed capital to some of the other pools; 2) no marketing of the pools to U.S. persons or from within the U.S. has been undertaken; 3) the pools will be operated in a manner consistent with Commission Rule 4.5(c)(2); and 4) the U.S. Directors will not engage in any other activities that would require registration under the Commodity Exchange Act. The Division also provided no-action relief to the U.S. affiliates of the foreign investment company that furnish commodity interest advisory services to pools because, among other things, the affiliates are registered securities investment advisers and will provide advisory services in accordance with Commission Rule 4.14(a)(8).
10/04/2000
00-96 PDF Image; Section 4m(1) - CPO and CTA Registration; No-Action
The Division of Trading and Markets issued a CPO registration no-action position to the management company of an offshore fund, notwithstanding the fact that the management company is owned by U.S. persons, based upon, among others, representations that: 1) neither the fund nor the management company was organized offshore to avoid CPO registration requirements; 2) no U.S. person will participate in the fund; 3) no marketing activities will be conducted from the U.S.; and 4) the Fund will be operated in a manner consistent with Rule 4.5(c)(2). The Division issued a CTA registration no-action position to the U.S.-based advisor of the fund based upon, among others, the foregoing representations and additionally that: 1) the CTA is registered as an investment adviser, and 2) it will comply with Rule 4.14(a)(8) in advising the fund.
09/25/2000
00-97 PDF Image; Section 4m(1); No-Action
The Division of Trading and Markets extended a previously-taken "no-action" position relieving a state-regulated insurance company and two trust companies from CPO and CTA registration requirements in connection with an estate planning device consisting of insurance contracts held in trust, the premium payments for which are invested in an insurance company separate account, a sub-account of which may invest in commodity pools. The no-action position was extended to include a second state-regulated insurance company under the same terms and conditions applicable to the insurance company involved in the original letter.
05/22/2000
00-98 PDF Image; CEA ? 4m(1), Regulation 4.10(d)(1); Interpretation
The Division of Trading and Markets confirmed that certain family limited partnerships would not be "pools" within the meaning and intent of Rule 4.10(d), and, consequently, the general partners of the partnerships would not be CPOs thereof. In addition, the Division also confirmed that none of the general partners would be required to register as CTAs either because: (1) they are not CTAs within the meaning in Section 1a(5) of the CEA, because they do not receive compensation or profit; or (2) they qualify for exemption from CTA registration under Section 4m(1) of the CEAct.
10/17/2000
00-99 PDF Image; Section 4m(1); No-Action
The Division of Trading and Markets took a CPO registration "no-action" position with respect to one of two co-managing members of four investor pools in a master-feeder fund structure based upon, among others, representations that: (1) the unregistered co-managing member would be excluded from commodity interest trading; (2) all CPO functions would be performed by the other (CPO-registered) co-managing members; (3) the unregistered co-managing member is not subject to statutory disqualification; and (4) cross acknowledgments were made by both co-managing members of joint and several liability for each other's CEA and/or Commission rule violations. All commodity interest trading activity would take place at the investee pool (master fund) level, for which the registered co-managing member is the CPO, and the investee pools would be advised by a CTA-registered affiliate of the registered co-managing member.
11/01/2000
00-100 PDF Image; Regulation 4.10(d)(1); Interpretation
The Division of Trading and Markets found that a limited partnership composed of family members was not a commodity pool within the means and intent of Rule 4.10(d)(1) and, consequently, that the General Partner was not a CPO thereof.
11/07/2000
00-101 PDF Image; Section 4f(b) of the CEAct and Commission Regulation 1.17(c)(5)(x); No-Action
The Division of Trading and Markets took a "no-action" position with respect to futures commission merchants (FCMs) or introducing brokers (IBs) that, in computing their respective adjusted net capital, do not take full capital charges, as set forth in Regulation 1.17(c)(5)(x), on open futures positions that are part of certain inter-exchange spread transactions involving futures contracts listed on the Cantor Financial Futures Exchange (Cantor). To be eligible for the relief, the inter-exchange spread must satisfy certain conditions, including that the Cantor and non-Cantor futures contracts have substantially similar terms and conditions and are based on the same underlying financial instruments.
12/01/2000
01-02 PDF Image; Section 4d(2) of the Act -- No-Action Position from FCM Registration; No-Action
The Division of Trading and Markets confirmed the continuation of an FCM registration no-action position to a registered IB (IB1) that had acquired the commodity interest trading business of another now-defunct IB (IB2). The FCM registration no-action position permits IB1, just as it had permitted IB2, to affect the transfer of funds via check from customers' securities to commodity interest accounts upon oral request. The no-action additionally permits IB1 to affect the transfer of funds via wire transfer from customers' securities to commodity interest accounts and to use an armored courier for the retrieval and delivery of checks. The relief was granted based upon representations made by IB1 that: 1) customers have provided pre-authorization in writing permitting the transfer of funds both ways between their commodity interest and securities accounts; 2) less than one percent of IB1's total revenue is derived from commodity interest-related activity; and 3) IB1 is not advertising its commodity interest-related activity but instead is offering these services to existing securities customers merely as a courtesy. The relief was granted on condition that IB1 adopt specified procedures designed to safeguard those customer funds required to be segregated, including detailed recordkeeping requirements concerning any transfers of funds.
11/14/2000
00-102 PDF Image; 4.22(c) & (d); Exemption
The CPO of a Fund requested an exemption from the requirement of Rule 4.22(d) that the Fund's 1999 Annual Report be audited, and exemption from the requirement of Rule 4.22(c) that the Fund distribute an annual report to participants. Based on the ownership structure, the managing member and the only investor of the Fund are synonymous. The investor submitted a consent waiver statement in support of the exemption. The Fund subsequently closed in August 2000 and the CPO requested the same exemptions for 2000.
11/13/2000
00-103 PDF Image; Section 2(a); No-Action
The Office of the General Counsel (OGC) issued a no-action letter that will permit the offer and sale in the U.S. of the SPI 200 futures contract based on the Standard & Poors/Australian Stock Exchange 200 Index traded on the Sydney Futures Exchange, Limited.
11/16/2000
00-104 PDF Image; Section 5 and 5a of the CEA; No-Action
The Division of Trading and Markets (Division) issued a letter granting no-action relief to permit Eurex Zurich Ltd. (Eurex CH) to make its electronic trading and order matching system, known as the System, available to its members in the U.S. without obtaining contract market designation pursuant to Section 5 and 5a of the CEA. Specially, the Division agreed not to recommend that the Commission institute enforcement action against Eurex CH or its members if Eurex CH makes the System available to its members: 1) who wish to trade for their proprietary accounts through the System in the Unites States; 2) who are registered futures commission merchants (FCMs) or who are exempt from registration pursuant to Rule 30.10 (Rule 30.10 Firms) and who wish to submit orders from U.S. customers for transmission to the System; and/or 3) who are registered FCMs or Rule 30.10 Firms who wish to accept orders from U.S. customers through automated order routing systems for submission to the System. The Division's no-action position is limited to contracts specifically delineated in the letter and is subject to compliance with the terms and conditions set forth therein.
11/15/2000
00-105 PDF Image; Section 4d(1); No-Action
The Division of Trading and Markets issued a no-action position, for failing to register as an IB, to an online company that provides an electronic trading platform where elevators and producers can negotiate to buy and sell cash grain, and as part of the platform the company offers an integration tool permitting elevators to be linked to their chosen FCM. The Division took this position based upon the company's representations that: 1) without this tool, elevators might not be willing to undertake the risks presented by purchasing cash grain through the trading platform; 2) this tool will facilitate as reasonable business purpose, i.e., the hedging of cash purchases by elevators; 3) the company has no involvement in selecting the FCMs that any elevator uses; and 4) the company does not receive any direct compensation from such FCMs.
11/22/2000
00-106 PDF Image; 7 U.S.C. Section 4d(2); Interpretation
Requestor inquired concerning: 1) the obligations of an FCM that is unable to meet its obligation to customers, but subsequently receives additional funds or property, and 2) the effect of the assignment of such obligation by a customer to a third party. The Division of Trading and Markets noted the prohibition against the use of the funds or property of any customer to purchase, margin, guarantee, or settle the trades or contracts or extend the credit of any other customer. This prohibition, taken together with the requirement that the funds and property of every customer be segregated and treated as belonging to such customer, mandates that if the segregated balance of any one customer falls into a deficit, the FCM must restore the amount of such deficit out of its own funds. This obligation continues even though an FCM does not possess sufficient funds to satisfy it. Any funds subsequently obtained by the FCM must be applied to this obligation. None of the foregoing principles is affected by an assignment, valid under state law, by a customer to a third party of the customer's claim against the FCM
12/08/2000
00-107 PDF Image; 4.22(d); Exemption
The CPO of a pool ceased trading in September 2000 closing the pool and liquidating the units of ownership. The CPO requested exemption from the requirement of Rule 4.22(d) that the pool's 2000 Annual Report be audited. The participants submitted consent waiver statements in support of the exemption. The exemption was granted upon condition that an unaudited 2000 Annual Report be provided to the participants, NFA and CFTC.
12/04/2000
00-108 PDF Image; Part 35 of the Commission's rules; No-Action
On December 4, 2000, the Division of Trading and Markets issued a letter granting no-action relief in connection with the operation of U.K.-based electronic trading platform for the trading of certain agreements on physical commodities for which there is no futures contract traded on any exchange in the U.S. or any other member country of the Organisation for Economic Co-Operation and Development. The platform will utilize an electronic trading and matching system that can be accessed through the Internet, and it will be available only to approved participants and authorized brokers entering orders on their behalf. Participants will be limited to commercial entities that qualify as "eligible participants" under specified provisions of Part 35 of the Commission's rules. The operation of the platform is subjected to oversight by U.K. authorities.
08/11/2000
01-08 PDF Image; Section 4m(1); No-Action
The Division of Trading and Markets took CPO and CTA no-action positions permitting a registered investment adviser to manage and advise a pension plan group trust for employees of the adviser's parent or corporate affiliates, the general account of an insurance company subsidiary of the adviser's parent, a trust holding pension plan assets for employees of a spun-off subsidiary of the adviser's parent, two pension plans for Canadian employees of the adviser's corporate affiliates, and a United Kingdom pension plan trust for employees of the adviser's parent and affiliates. The Division declined to extend the no-action position to permit the entities managed or advised by the adviser to accept pension plan assets from entities unaffiliated with the adviser's parent.

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