CFTC Staff Letters
CFTC Staff Letters provides Letters from 2008 and later. For Letters published before 2008 visit the Letters Archive page.
| Description | |
|---|---|
 26-14 |
Letter Type: No-Action Division: DMO Regulation Parts: 38.8, 38.10, 38.951, 39.20, 43, 45 Tags: Reporting, Swap, Swap Data, Swaps, Event Contract, Part 43, Part 45 Issuance Date: Description: No-action position with respect to Part 43 and Part 45 reporting, as well as related sections of Parts 38 and 39, for certain binary and variable payout event contracts. See also: Request Letter 1 Request Letter 2 Request Letter 3 Request Letter 4 Requester(s): CFTC |
| 26-13 |
Letter Type: No-Action Division: DMO, DCR Regulation Parts: 38.8, 38.10, 38.951, 39.20, 43, 45 Tags: Fully-collateralized, Recordkeeping, Reporting, Swap, Swap Data, Swaps, Event Contract, Part 43, Binary Option, Part 45 Issuance Date: Description: The Divisions will not recommend that the Commission initiate an enforcement action against Railbird, Bitnomial, or their participants, for failure to comply with Commission regulations 38.8(b), 38.10, 38.951 (only to the extent that regulation 38.951 requires compliance with Part 45 of the CFTC’s regulations), and 39.20(b)(2), as well as the applicable provisions of Parts 43 and 45 of the CFTC’s regulations, or the requirements of the relevant CEA provisions pursuant to which the Relevant Regulations were promulgated, with respect to Railbird Contracts, subject to certain conditions. See also: Request Letter Requester(s): BTNL CLEAR, RAILBIRDX |
| 26-12 |
Letter Type: No-Action Division: DMO, DCR Regulation Parts: 38.8, 38.10, 38.951, 39.20, 43, 45 Tags: Swap, Swap Data, Swaps, Event Contract, Part 43, Part 45 Issuance Date: Description: Gemini Titan LLC (“Titan”) and Gemini Olympus, LLC (“Olympus”) request a no-action position, on their own behalf and on behalf of their participants, from the swap data reporting and recordkeeping requirements of regulations 38.8(b), 38.10, 38.951 (to the extent that regulation 38.951 requires compliance with Part 45 of the Commission’s regulations), 39.20(b)(2), along with Parts 43 and 45 of the Commission’s regulations. Titan and Olympus request a no-action position with respect to reporting contracts with a binary payout structure and contracts with a variable payout structure with the features described in the letter, traded and cleared pursuant to Titan and Olympus’s rules. See also: Request Letter Requester(s): GEM, GO |
| 26-11 |
Letter Type: No-Action Division: DCR Regulation Parts: 39.19 Tags: DCO, Reporting Issuance Date: Description: No-action letter to Nodal Clear extending the compliance deadline for the daily reporting requirements under Regulation 39.19(c)(1). See also: Request Letter Requester(s): NODALCL |
| 26-10 |
Letter Type: No-Action Division: DMO Regulation Parts: 2(h)(8), 5h(a)(1), 37.3 Tags: Foreign, SEF, Trade Execution Requirement, SEF Registration, Exempt SEF Issuance Date: Description: Amendment of Appendix A of Staff Letter 24-11 to add two UK swap trading facilities to Staff Letter 24-11. Requester(s): CFTC, FCA, HMT |
| 26-09 |
Letter Type: No-Action Division: MPD Regulation Parts: 4d, 4k, 3.10, 3.12 Tags: DCM, FCM, IB, Registration, Associated Persons, solicit Issuance Date: Description: MPD no-action position, subject to certain specified conditions, on introducing broker (IB) and associated person registration for a provider of self-custodial crypto asset wallet software that proposes to provide and market software to facilitate trading by its users with registered futures commission merchants and IBs and designated contract markets. See also: Request Letter Requester(s): PHANTOM |
| 26-08 |
Letter Type: Advisories Division: DMO Regulation Parts: 5c, 38.153, 38.157, 38.158, 38.200, 38.250, 38.254, 38 Appendix C, 40.2, 40.3, 180.1, 180.2 Tags: DCM, Event Contract Issuance Date: Description: DMO Staff Advisory Regarding Prediction Markets Requester(s): CFTC |
| 26-07 |
Letter Type: No-Action Division: DMO Regulation Parts: 5(d)(20), 38.1101 Tags: DCM, System Safeguards, Business Continuity-Disaster Recovery Issuance Date: Description: The Division of Market Oversight (“Division”) of the Commodity Futures Trading Commission (“Commission”) is issuing this letter in response to a no-action letter request from Coinbase Derivatives, LLC (“COIN”), a designated contract market (“DCM”), submitted pursuant to Commission regulation 140.99. COIN seeks a no-action position with respect to certain requirements under Commodity Exchange Act (“CEA”) Section 5(d)(20), and Commission regulation 38.1051(c) addressing backup facilities. See also: Request Letter Requester(s): COINBASE |
| 26-06 |
Letter Type: No-Action Division: MPD Regulation Parts: 4m(1), 4 Tags: Commodity Pool, CPO, Registration, Delegation Issuance Date: Description: No-action position on commodity pool operator and commodity trading advisor registration for certain private funds and subject to certain conditions, with additional revision to address CPO delegation arrangements. See also: Request Letter Requester(s): MFA |
| 26-05 |
Letter Type: No-Action Division: MPD Regulation Parts: 1.17, 1.20, 1.23, 1.32, 22.2, 22.17, 30.7 Tags: Collateral, FCM, Customer Funds Issuance Date: Description: Staff No-Action Position with respect to FCMs that accept certain non-securities digital assets as margin collateral and (a) take into account the value of such digital assets for purposes of certain regulatory requirements, subject to conditions or (b) deposit payment stablecoins as residual interest, subject to conditions. Note that this is a re-issuance of Staff Letter 25-40 to specify that a national trust bank may be a permitted issuer of a payment stablecoin for purposes of the no-action position taken in Letter 25-40. See also: Request Letter Requester(s): CFM |