Letters

Date Title
18-19 PDF Image; Commission Regulation 1.17; No-Action
Commission Regulation 1.17 – Staff no-action position regarding the treatment of operating leases caused by a change in accounting principles.
18-18 PDF Image; CEA Section 5b(a) and the Commission regulations thereunder; No-Action
Extension of time-limited no-action relief for Shanghai Clearing House with regard to Section 5b(a) of the Commodity Exchange Act and Commission Regulations thereunder.
18-14 PDF Image; CEA Section 5, 5b, 5c, and 5h, and Commission Regulations 40.2 and 40.3; Advisories
Advisory for exchanges and clearinghouses with respect to Virtual Currency Derivative Product Listings.
18-13 PDF Image; Sections 1a(33)(B) and 1a(49)(D) of the Commodity Exchange Act and CFTC Regulation 1.3; No-Action
No-action relief for non-U.S. persons that are neither guaranteed affiliates nor conduit affiliates of a U.S. person from the requirement to count swaps with international financial institutions towards the de minimis thresholds for the swap dealer and major swap participant definitions.  
18-15 PDF Image; CEA Section 4m(1); No-Action
No-action relief granted to an entity from CPO registration with respect to several commodity pools for which it serves as trustee; provided, that it delegates the CPO responsibilities to a registered CPO, subject to certain conditions.
18-12 PDF Image; Commission Regulation 150.4(a) and 150.4(b)(1); Interpretative
The staff letter confirms that, for purposes of applying the position limits set forth in CFTC Regulation 150.2, when an institutional investor qualifies for the Regulation 150.4(b)(1) exemption from position aggregation with respect to their investment in a fund, the institutional investor is not required to look through its investment in a fund to aggregate commodity interest positions of an underlying portfolio company in which the institutional investor may hold a 10 percent or greater indirect interest (via its investment in the fund).  
18-17 PDF Image; Commission regulation 4.7(b)(2); Exemption
Exemptive relief granted to a CPO to permit the CPO to provide monthly account statements to participants within 45 days of the month end rather than quarterly account statement within 30 days of the quarter end pursuant to Commission regulation 4.7(b)(2).
18-11 PDF Image; CFTC Regulations 4.22(d) and 4.27(c); Other Written Communications
Rescission of CFTC Staff Letter No. 16-47
18-10 PDF Image; CFTC Regulation 4.7(b)(3); Exemption
Previous annual report exemptive relief granted to a CPO extended to an additional subsidiary pool; condition in previous exemptive relief with respect to an existing subsidiary pool removed based on changed circumstances.  
18-09 PDF Image; Commission Regulations 4.7 and 4.22;; Exemption
Exemptive relief from the provisions of Commission Regulations 4.7 and 4.22 to prepare an onshore feeder fund’s financial statements in accordance with U.S. GAAP