Font Size: AAA // Print // Bookmark

No-Action Letters

Date
No-Action Letters
01/03/2014
14-01 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, and Parts 43 and 50 of the Commission’s Regulations; No-Action
Extension of No-Action Relief: Transaction-Level Requirements for Non-U.S. Swap Dealers
01/10/2014
14-02 PDF Image; Commission Regulations 1.20, 22.2, and 30.7; No-Action
No-action relief from compliance with certain conditions associated with the receipt of customer funds by FCMs.
01/10/2014
14-03 PDF Image; Commission Regulation 30.7; No-Action
No-action relief regarding the limitation on the holding of customer funds outside the U.S. under Regulation 30.7.
02/06/2014
14-07 PDF Image; Section 5b(a) of the CEA; No-Action
The Division of Clearing and Risk issued a letter stating that it will not recommend that the Commission take enforcement action against ASX Clear (Futures) Pty Limited for failure to register as a derivatives clearing organization pursuant to Section 5b(a) of the Commodity Exchange Act in connection with the clearing of certain interest rate swaps.
01/10/2014
14-08 PDF Image; Commission Regulation 30.7; No-Action
Time-limited no-action relief granted to a registered futures commission merchant regarding the maintenance of certain Rule 30.7 accounts.
02/10/2014
14-12 PDF Image; CEA §2(h)(8), CEA §5(d)(9) and Commission Regulation §37.9; No-Action
The Division is issuing a letter providing time-limited no-action relief to: (1) entities or counterparties transacting “package transactions” from the requirements of CEA section 2(h)(8); and (2) SEFs and DCMs, trading “package transactions” from the requirements of § 37.9 of the Commission’s regulations and CEA section 5(d)(9), respectively, until 11:59 p.m. (eastern time) May 15, 2014. This relief is intended to enable market participants to continue efforts towards complying with the trade execution requirement and to allow the Division to obtain additional information on package transactions, in part, from a public roundtable on February 12, 2014.
02/12/2014
14-15 PDF Image; CEA sections 2(h)(8) and 5h(a)(1); Commission Regulation 37.3(a)(1); No-Action
Time-Limited No-Action Relief with respect to Swaps Trading on Certain Multilateral Trading Facilities Overseen by Competent Authorities Designated by European Union Member States
02/12/2014
14-16 PDF Image; CEA sections 2(h)(8) and 5h(a)(1); Commission Regulations 37.3(a)(1), parts 23, 43 and 45; No-Action
Conditional No-Action Relief with respect to Swaps Trading on Certain Multilateral Trading Facilities Overseen by Competent Authorities Designated by European Union Member States
02/20/2014
14-18 PDF Image; Section 4(c)(6); No-Action
No-Action Relief with Respect to Certain Commodity Exchange Act Provisions That May Apply to Southwest Power Pool, Inc. and/or Its Participants
03/06/2014
14-25 PDF Image; 50.52; No-Action
No-action letter extending the time-limitation contained in an alternative compliance framework available to certain affiliated counterparties pursuant to Commission regulation 50.52(b)(4)(ii)-(iii).
03/06/2014
14-26 PDF Image; Commission Regulation 50.52 , CEA 2(h)(8); No-Action
No-action letter providing time-limited no-action relief from the requirements of the trade execution requirement in Commodity Exchange Act (CEA) section 2(h)(8) to Eligible Affiliate Counterparties, as defined in Commission regulation 50.52(a) of the Commission’s regulations, that engage in swap transactions with one another that involve a swap subject to the trade execution requirement.
03/10/2014
14-27 PDF Image; Commodity Exchange Act Sections 5b(a) and 2(h)(1)(A); No-Action
Extension of Time-Limited No-Action Relief to Eurex Clearing with Regard to Sections 5b(a) and 2(h)(1)(A) of the Commodity Exchange Act and Implementing Regulations Thereunder.
02/28/2014
14-28 PDF Image; CEA Section 4m(1); No-Action
The Division of Swap Dealer and Intermediary Oversight (Division) took a CPO registration no-action position with respect to the operation of certain collective trading vehicles by either of two corporations (A and B) entirely controlled by a non-profit corporation (C) that is the coordinating organization for a denomination’s churches. The collective trading vehicles would commingle assets of church plans (within the definition of Regulation 4.5) associated with the denomination’s churches, together with endowments and other assets of certain non- profit corporations entirely controlled by C. Although the collective trading vehicles would be pools, the Division believed that requiring CPO registration would serve no substantial regulatory purpose because persons who would be subject to background checks and proficiency examinations would already have been vetted and hired by A, B or C, and because any Disclosure Document would be delivered by A or B to the other or to C.
03/18/2014
14-29 PDF Image; 4m(1) – No-Action Position from CPO Registration; No-Action
The Division of Swap Dealer and Intermediary Oversight confirmed the availability of Staff Letter 00-10, which provided CPO registration relief to a university's cooperative extension service, its agents and employees, permitting them to offer courses that would allow certain students to trade commodity interests through participation in a trading club, notwithstanding certain amendments to the course and trading club criteria.
03/21/2014
14-31 PDF Image; CEA sections 2(h)(8) and 5h(a)(1); Commission Regulation 37.3(a)(1); No-Action
Extension of Time-Limited No-Action Relief with respect to Swaps Trading on Certain Multilateral Trading Facilities Overseen by Competent Authorities Designated by European Union Member States
03/21/2014
14-32 PDF Image; Commission Regulation 3.3; No-Action
No-Action Relief from Compliance with Certain Requirements of Commission Regulation 3.3 Relating to the Chief Compliance Officer Annual Report (Mitsui & Co. Precious Metals, Inc.)
03/21/2014
14-33 PDF Image; Commission Regulation 1.35(a); No-Action
Time-Limited No-Action Relief for Certain Members of a Designated Contract Market from the Requirement to Record Oral Communications, Pursuant to Commission Regulation 1.35(a), in Connection with the Execution of Swap Transactions
03/21/2014
14-34 PDF Image; Commission Regulation 1.3(ggg); No-Action
Staff No-Action Relief: Revised Relief from the De Minimis Threshold for Certain Swaps with Utility Special Entities
03/27/2014
14-38 PDF Image; Section 5b; No-Action
Extension of no-action relief granted by DCR on September 23, 2013, allowing LCH.Clearnet Ltd to clear swaps executed on designated contract markets and swap execution facilities.
03/27/2014
14-39 PDF Image; Sections 5b(a) and 5(d)(11)(A) of the CEA; No-Action
Extension of joint no-action relief granted by DCR and DMO on September 27, 2013, allowing LCH.Clearnet Ltd to clear contracts listed for trading on Nodal Exchange LLC.
03/28/2014
14-41 PDF Image; 4d(f); No-Action
The Division of Clearing and Risk issued a letter stating that it will not recommend that the Commission take enforcement action against Singapore Exchange Derivatives Clearing Limited (SGX-DC) clearing members for failing to comply with the Commodity Exchange Act Section 4d(f)(1) registration requirements in carrying existing positions and accepting for clearing offsetting positions in certain commodity swaps for U.S. customers or customers of FCMs that clear through an FCM omnibus customer account; or SGX-DC for engaging in activities related to its clearing members carrying and accepting for clearing such customer positions.
04/07/2014
14-45 PDF Image; Commission Regulations 1.20, 22.2, and 30.7; No-Action
Extension of previously issued no-action.
04/09/2014
14-46 PDF Image; CEA sections 2(h)(8) and 5h(a)(1); Commission Regulations 37.3(a)(1); parts 23, 43 and 45; No-Action
Conditional No-Action Relief with respect to Swaps Trading on Certain Multilateral Trading Facilities Overseen by Authorities Designated by European Union Member States
04/18/2014
14-50 PDF Image; Rule 38.152; No-Action
The Division of Clearing and Risk and Division of Market Oversight (together, “the Divisions”) issued a no-action letter providing time-limited and specific relief for designated contract markets (“DCMs”) from compliance with certain requirements of Commission Regulation 38.152, including a prohibition against certain abusive trading practices, including pre-arranged trading.

See Also:

OpenGov Logo

CFTC's Commitment to Open Government

Gavel and Book

Follow the Status of Enforcement Actions