CFTC Staff Letters

CFTC Staff Letters provides Letters from 2008 and later. For Letters published before 2008 visit the Letters Archive page.

PDF Description
PDF Image 24-07 Letter Type: No-Action
Division: DCR, MPD
Regulation Parts: 1.3, 1.17, 1.20, 1.32, 1.58, 1.73, 22.2, 30.2, 30.7, 39.13
Tags: Risk Management, Separate Account Treatment
Issuance Date:
Description:

Accordingly, the conditional no-action position with respect to Regulation 39.13(g)(8)(iii) contained in CFTC Letter No. 19-17 is now further extended until the earlier of (a) June 30, 2025 or (b) the effective date of any final Commission action relating to the Second Proposal.


See also: Request Letter
Requester(s): FIA
PDF Image 24-06 Letter Type: No-Action
Division: DMO
Regulation Parts: 43, 43.4, 43.6
Tags: Block Trades, Reporting, SDR, Swap Data, Swaps, Part 43
Issuance Date:
Description:

DMO is extending a time-limited no-action position with respect to the compliance date for the November 25, 2020 amendments to certain rules pertaining to block sizes and cap sizes in Part 43.


See also: Request Letter
Requester(s): CMESDR, DTCC, ICE SDR, KOR
PDF Image 24-05 Letter Type: Exemption
Division: MPD
Regulation Parts: 4.7
Tags: Commodity Pool, CPO, Disclosures, Exemptions, Funds, Pool Participant, Reporting
Issuance Date:
Description:

Exemptive relief permitting a limited number of non-QEP senior employees of the CPO to be treated as QEPs, subject to several specific conditions, for purposes of investing in employee securities companies the CPO operates as 4.7 pools.


See also: Request Letter
Requester(s): TWO SIGMA
PDF Image 24-04 Letter Type: Exemption
Division: MPD
Regulation Parts: 4.7(b)(3), 4.22
Tags: Annual Report, Commodity Pool, CPO
Issuance Date:
Description:

Exemptive relief from the requirement in Regulations 4.7(b)(3) and 4.22(c) to provide an audited Annual Report and Financial Statements when liquidating a commodity pool, if the pool instead provides a combined 13-month Annual Report and Financial Statements.


See also: Request Letter
Requester(s): III CAP
PDF Image 24-03 Letter Type: Advisories
Division: DMO
Regulation Parts: 30.13, 48
Tags: Foreign Boards of Trade
Issuance Date:
Description:

Advisory on Transition to Portal Filings for Registered Foreign Boards of Trade


PDF Image 24-02 Letter Type: No-Action
Division: MPD
Regulation Parts: 23.431
Tags: Compliance, Counterparty, Disclosures, Swap Dealer, External Business Conduct, Business Conduct Standards, Documentation, SOFR
Issuance Date:
Description:

No-action position for registered swap dealers and major swap participants that enter into certain swaps referencing the Secured Overnight Financing Rate (described in the letter) relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission regulation 23.431(a)(3)(i).


See also: Request Letter
Requester(s): ARRC
PDF Image 24-01 Letter Type: No-Action, Exemption
Division: DCR
Regulation Parts: 4d(f), 1.20, 1.49, 22.5
Tags:
Issuance Date:
Description:

No-action relief for LCH SA with regard to Regulations 1.20(g)(4) and 22.5, and an exemption from the requirements of Regulation 1.49(d)(3) for customer accounts held at the Banque de France.


Requester(s): LCHSA
PDF Image 23-16 Letter Type: Advisories
Division: DMO, DCR, MPD
Regulation Parts: 37, 38, 39
Tags: Affiliates, Compliance, DCM, DCO, SEF
Issuance Date:
Description:

The advisory reminds designated contract markets, derivatives clearing organizations, and swap execution facilities that have an affiliated intermediary or trading entity, as well as the affiliated intermediary or trading entities themselves, of their obligations to ensure compliance with existing statutory and regulatory requirements with this affiliate relationship in mind. The advisory also informs market participants that CFTC staff closely scrutinizes how these types of affiliate relationships are addressed when reviewing applications for registration or designation; conducting examinations and rule reviews; and through other supervisory means. Market participants are invited to contact the relevant Division if there are concerns regarding these types of affiliate relationships.


Requester(s): CFTC
PDF Image 23-15 Letter Type: No-Action
Division: DMO
Regulation Parts: 43, 43.4, 43.6
Tags: Block Trades, Reporting, SDR, Swap Data, Swaps, Part 43
Issuance Date:
Description:

DMO is extending a time-limited no-action position with respect to the compliance date for the November 25, 2020 amendments to certain rules pertaining to block thresholds and cap sizes in Part 43.
Request Letter No. 2
Request Letter No. 3


See also: Request Letter
Requester(s): CMESDR, DTCC, ICE SDR, KOR
PDF Image 23-14 Letter Type: No-Action
Division: DMO
Regulation Parts: 17, 18, 20
Tags: Reporting, Ownership and Control, Part 17, Part 18, Part 20
Issuance Date:
Description:

Extension of conditional time-limited no-action position for filing certain information for ownership and control reports required by Parts 17, 18, and 20 of the Commission's regulations


See also: Request Letter
Requester(s): CMC, FIA, ISDA