CFTC Staff Letters
CFTC Staff Letters provides Letters from 2008 and later. For Letters published before 2008 visit the Letters Archive page.
| Description | |
|---|---|
 26-04 |
Letter Type: Advisories Division: DMO, DCR, MPD Regulation Parts: 1, 1.55, 38, 39 Tags: DCM, DCO, Event Contract, Withdrawal Issuance Date: Description: Withdrawal of CFTC Staff Advisory 25-36. Requester(s): CFTC |
| 26-03 |
Letter Type: Interpretative Division: DCR, MPD Regulation Parts: 2(h), 2(h)(1), 2(h)(1)(A), 4s(e), 23.150 - 23.161, 50.2, 50.4, 140.99 Tags: Clearing, Clearing Requirement, Margin, Legacy Swaps Issuance Date: Description: Joint MPD and DCR interpretative letter addressing the effect of a merger conducted as part of Morgan Stanley’s internal reorganization on the status of certain legacy swaps. Based on the facts and circumstances of the merger as described in the letter, the divisions concluded the swaps at issue retain their legacy swap status under the Commission’s uncleared swap margin and swap clearing requirements. See also: Request Letter Requester(s): MORGSTAN |
| 26-02 |
Letter Type: No-Action Division: DMO Regulation Parts: 17 Tags: FCM, Large Trader, Foreign Broker, Part 17 Issuance Date: Description: No-action position with respect to timing for implementation of the Commission's 2024 Part 17 large trader reporting final rule. See also: Request Letter Requester(s): FIA |
| 26-01 |
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 bounded swaps executed on or pursuant to the rules of Bitnomial Exchange, LLC and cleared through Bitnomial Clearinghouse, LLC. See also: Request Letter Requester(s): BTNL, BTNL CLEAR |
| 25-51 |
Letter Type: No-Action Division: MPD Regulation Parts: 1a(49), 1.3 Tags: De Minimis, Registration, SD, Swap Dealer Issuance Date: Description: No-action position with respect to the exclusion of energy commodity end user swaps from the swap dealer de minimis calculation. See also: Request Letter Requester(s): EEI |
| 25-50 |
Letter Type: No-Action Division: MPD Regulation Parts: 4m(1), 4.13, 4.14 Tags: Commodity Pool, CPO, CTA, SEC Issuance Date: Description: No-action position on commodity pool operator and commodity trading advisor registration for certain private funds and subject to certain conditions. See also: Request Letter Requester(s): MFA |
| 25-49 |
Letter Type: No-Action Division: MPD Regulation Parts: 23 Subpart H Tags: Cleared Swaps, Exempt DCO, External Business Conduct, Business Conduct Standards, Documentation, Swap Trading Relationship Documentation, Cross-border, Special Entity, Exempt SEF Issuance Date: Description: No-action position for intended-to-be-cleared swaps traded on Eligible UK Trading Venues (as defined in the letter). Requester(s): CFTC |
| 25-48 |
Letter Type: No-Action Division: DMO 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: QCX LLC, d/b/a Polymarket US, and QC Clearing LLC, d/b/a Polymarket Clearing (collectively, “Polymarket”) requested to amend Staff Letter 25-28. Staff Letter 25-28 granted Polymarket’s request for a no-action position with respect to the swap data reporting and recordkeeping requirements of sections 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), and Parts 43 and 45 of the Commission’s regulations (collectively, the “Relevant Regulations”). Polymarket has now requested that the Divisions modify the no-action position granted in Staff Letter 25-28 to remove condition 6, which provides that “[n]o [Polymarket] participant clears a QCEX Contract through a third-party clearing member.” See also: Request Letter Requester(s): PM US, PMC, QCCLEAR, QCX |
| 25-47 |
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 binary options and variable payout contracts executed on or pursuant to the rules of Aristotle Exchange DCM, Inc and cleared through Aristotle Exchange DCO, Inc. See also: Request Letter Requester(s): ARIS, ARISDCO |
| 25-46 |
Letter Type: No-Action Division: DMO Regulation Parts: 38.3, 40.1 Tags: DCM, Dormancy Issuance Date: Description: Small Exchange, Inc. – Time-Limited No-Action Position with respect to Certain Provisions under the Commission’s Dormancy Framework for Registered Entities. See also: Request Letter Requester(s): SMFE |