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No-Action Letters

Date
No-Action Letters
01/08/2016
16-01 PDF Image; Sections 2(h)(1) and (7) of the CEA; CFTC regulation 50.50; No-Action
No-action relief from the swap clearing requirement for a bank holding company or savings and loan holding company with consolidated assets of $10 billion or less.
01/08/2016
16-02 PDF Image; Sections 2(h)(1) and (7) of the CEA; CFTC regulation 50.4; and CFTC regulation 50.50.; No-Action
No-action relief from certain categories of the swap clearing requirement for certified community development financial institutions.
01/15/2016
16-03 PDF Image; Parts 20, 45 and 46 of the Commission’s regulations; No-Action
CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief 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.
02/01/2016
16-04 PDF Image; Regulation 39.12(b)(7), CEA Sections 5b(c)(2)(A) and 5b(c)(2)(C); No-Action
Grant of No-Action Relief with Regard to Regulations Implementing Sections 5b(c)(2)(A) and 5b(c)(2)(C) of the Commodity Exchange Act.
02/01/2016
16-05 PDF Image; Regulations 1.20(g)(4), 22.5 and 1.49(d)(3); No-Action; Exemption
No-action relief for Eurex Clearing AG with regard to Regulation 1.20(g)(4), and an exemption from the requirements of Regulation 1.49(d)(3) for customer accounts held at the Deutsche Bundesbank.
02/09/2016
16-06 PDF Image; Regulation 39.19(b)(1); No-Action
The CFTC’s Division of Clearing and Risk (the “Division”) issued a no-action letter providing Singapore Exchange Derivatives Clearing Limited (“SGX-DC”) with time-limited no-action relief from Regulation 39.19(b)(1). Under the no-action relief, while SGX-DC completes an overhaul of its derivatives trading and clearing systems, SGX-DC will submit required information in CSV format instead of in FIXML format.
01/13/2016
16-07 PDF Image; CEA Section 4m(1), Regulations 4.5 and 4.6; No-Action
The Division of Swap Dealer and Intermediary Oversight provided no-action relief from CPO and CTA registration to the Board of Trustees of a pension plan group trust comprised of two plans: one that is a “qualifying entity” under Regulation 4.5, and another that is “not construed to be a pool” under that same rule.
02/12/2016
16-08 PDF Image; Commission regulation 3.10(c)(3); No-Action
The Division of Swap Dealer and Intermediary Oversight is issuing a no-action letter that would permit IBs, CPOs, and CTAs to rely on the exemption from registration in Commission Regulation 3.10(c)(3)(i) if their activities include swaps that are not subject to a Commission clearing requirement even if such swaps are not submitted for clearing through a registered FCM.
02/12/2016
16-09 PDF Image; Section 4(c)(6); No-Action
Extension of time-limited no-action relief with respect to certain Commodity Exchange Act provisions that may apply to Southwest Power Pool, Inc. and/or its participants.
02/18/2016
16-10 PDF Image; Commission Regulation 32.3(b)(2); No-Action
Time-limited no-action relief for end users from the Form TO filing requirement under Commission regulation § 32.3(b)(2).
02/29/2016
16-23 PDF Image; Regulation 1.57(a)(1); No-Action
The Division of Swap Dealer and Intermediary Oversight took a no-action position with respect to IBs guaranteed by a certain FCM, where the IBs would introduce ECP swap counterparties to each other, without opening or carrying customer accounts with the guarantor FCM. For uncleared swaps, no FCM would be involved in the transaction, and for cleared swaps, each counterparty would use an FCM for clearing that the counterparty had selected. The guarantor FCM would remain well-capitalized for the risk undertaken, and would be jointly and severally liable for all obligations of each of the guaranteed IBs with respect to their solicitation of swaps orders.
03/14/2016
16-25 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. 15-25 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.
03/16/2016
16-26 PDF Image; Part 22; Regulations 39.12(b)(6); 39.13(g)(8)(i); 39.13(g)(8)(ii); 39.12(a)(2)(iii); 39.12(b)(7); 39.13(h)(5); 39.11(f).; No-Action
The CFTC’s Division of Clearing and Risk (the “Division”) issued a no-action letter providing limited no-action relief for derivatives clearing organizations (“DCOs”) that are registered with the Commission and are authorized to operate as central counterparties (“CCPs”) in the EU from the application of Commission regulations to discrete aspects of their non-U.S. clearing activities.
03/15/2016
16-27 PDF Image; Section 4(c)(6); No-Action
Extension of Time-Limited No-Action Relief with Respect to Certain Commodity Exchange Act Provisions That May Apply to Southwest Power Pool, Inc. and/or Its Participants.
03/30/2016
16-28 PDF Image; CEA Section 4s(k)(3); CFTC Regulation 3.3(f)(2); No-Action
No-Action Relief from the Timing Requirements of Commission Regulation 3.3(f)(2) Relating to Annual Reports by Chief Compliance Officers for Commerzbank AG.
03/30/2016
16-29 PDF Image; CEA Section 4s(k)(3); CFTC Regulation 3.3(f)(2); No-Action
No-Action Relief from the Timing Requirements of Commission Regulation 3.3(f)(2) Relating to Annual Reports by Chief Compliance Officers for Deutsche Bank AG.
04/08/2016
16-32 PDF Image; Parts 17, 18 and 20 of the Commission’s Regulations; No-Action
No-action relief related to data reporting requirements under OCR Final Rule.
04/08/2016
16-33 PDF Image; Part 17 of the Commission’s Regulations; No-Action
No-action relief related to data masking of information required to be reported under OCR Final Rule.
03/31/2016
16-46 PDF Image; CEA Section 4m(1); No-Action
Consistent with CFTC Staff Letters 12-37 and 14-143, and its past practice in this area, the Division granted no-action relief from CPO and CTA registration to a family office that provides investment management and advisory services to a single family.
05/12/2016
16-52 PDF Image; CEA section 5h(a)(1); Commission Regulation 37.3(a)(1); No-Action
Extension of conditional time-limited no-action relief for Yieldbroker Pty Limited with regard to Section 5h(a)(1) of the Commodity Exchange Act and Commission Regulation 37.3(a)(1) until September 15, 2016.
05/31/2016
16-56 PDF Image; CEA Section 5b(a) and the Commission regulations thereunder; No-Action
Time-limited no-action relief for Shanghai Clearing House with regard to Section 5b(a) of the Commodity Exchange Act and Commission Regulations thereunder.
06/10/2016
16-58 PDF Image; Commission Regulations 37.9(a)(2), 37.203, 38.152, and 38.500; No-Action
DMO and DCR are extending the relief provided in CFTC Letter No. 15-24 and enabling SEFs and DCMs to address clerical and operational errors.
06/21/2016
16-59 PDF Image; Regulations 1.20(g)(4), 22.5 and 1.49(d)(3); No-Action; Exemption
No-action relief for Chicago Mercantile Exchange, Inc. with regard to Regulation 1.20(g)(4), and an exemption from the requirements of Regulation 1.49(d)(3) for customer accounts held at the Bank of Canada.
08/04/2016
16-64 PDF Image; Commission Regulations 23.202, 23.205, 23.400 to 23.451, 23.501, 23.502, 23.503, 23.504, 23.505, 23.506, 23.610, 23.701 to 23.704, and parts 37, 38, 43, and 50; No-Action
Extension of No-Action Relief: Transaction-Level Requirements for Non-U.S. Swap Dealers
08/08/2016
16-68 PDF Image; CFTC Regulation 1.25; No-Action
No-Action relief for FCMs with respect to the investment of customer funds in certain money market funds under CFTC Regulation 1.25.
09/01/2016
16-70 PDF Image; Commission Regulation 23.157; No-Action
Temporary no-action relief regarding custodial arrangements for swap dealers subject to September 1, 2016 compliance date for margin for uncleared swaps.
08/23/2016
16-71 PDF Image; 17 CFR 23.150 -23.161; No-Action
Portfolio margining of uncleared swaps and security-based swaps.
09/14/2016
16-72 PDF Image; CEA sections 2(h)(8), 5h(a)(1); Commission Regulation 37.3(a)(1), parts 23, 43 and 45; No-Action
Conditional no-action relief related to CFTC No-Action Letter No. 15-29 with respect to swaps trading on Yieldbroker Pty Limited
09/15/2016
16-73 PDF Image; Section 4(c)(6); No-Action
Extension of Time-Limited No-Action Relief with Respect to Certain Commodity Exchange Act Provisions That May Apply to Southwest Power Pool, Inc. and/or Its Participants

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