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 Image21-09 Letter Type: No-Action
Division: DMO, DCR, DOD, MPD
Regulation Parts: 2(h)(8), 23, 23.202, 23.205, 23 Subpart I, 23.500, 23.501, 23.502, 23.503, 23.504, 23.505, 23.506, 23.610, 23 Subpart L, 23.700, 23.701, 23.702, 23.703, 23.704, 37, 38, 43, 50
Tags: SD, Brexit, Cross-border
Issuance Date:
Description:

Brexit-related time limited no-action position with respect to certain swap dealer transaction-level requirements

PDF Image21-06 Letter Type: No-Action
Division: MPD
Regulation Parts: 3
Tags: Commodity Pool, CPO, CTA, Registration
Issuance Date:
Description:

No-action relief granted from CPO and CTA registration to an entity that uses swaps in connection with its acquisition of biopharmaceutical royalties.

PDF Image21-05 Letter Type: No-Action
Division: DMO, MPD
Regulation Parts: 5(d)(4), 5(d)(10), 1.3, 1.35, 38.250, 38.251, 38.252, 38.253, 155.3
Tags: FCM, IB, Recordkeeping, Registration, Floor broker, COVID-19, Audit Trail
Issuance Date:
Description:

Partial continuation of no-action positions to facilitate physical separation of registrant personnel in response to the COVID-19 pandemic

PDF Image21-04 Letter Type: No-Action
Division: DMO, MPD
Regulation Parts: 5(d)(4), 5(d)(10), 1.35, 38.250, 38.251, 38.252, 38.253, 38.254, 38.255, 38.256, 38.553
Tags: Recordkeeping, COVID-19, Audit Trail
Issuance Date:
Description:

No-action positions for floor brokers and introducing brokers from oral recordkeeping requirements and designated contract markets from audit trail requirements in continued response to the COVID-19 pandemic

PDF Image21-02 Letter Type: No-Action
Division: MPD
Regulation Parts: 1.25
Tags: FCM, Customer Funds
Issuance Date:
Description:

Time-Limited No-Action relief to FCMs from Regulation 1.25 for Investments in Securities with an Adjustable Rate of Interest Benchmarked to the Secured Overnight Financing Rate

PDF Image21-01 Letter Type: No-Action
Division: DCR
Regulation Parts: 39.19
Tags: DCO, Reporting
Issuance Date:
Description:

Temporary no-action relief for registered derivatives clearing organizations from the amended daily reporting requirements in CFTC Regulation 39.19. This relief expires on January 27, 2022.

PDF Image20-46 Letter Type: No-Action
Division: DCR
Regulation Parts: 5b(a)
Tags: DCO, Registration
Issuance Date:
Description:

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.

PDF Image20-45 Letter Type: No-Action
Division: DMO, DOD
Regulation Parts: 2(h)(8), 50.52
Tags: Affiliates, Clearing Requirement, Swaps, Trade Execution Requirement
Issuance Date:
Description:

No-action letter extending relief from section 2(h)(8) of the Commodity Exchange Act for any eligible affiliate counterparty that executes a swap transaction with another eligible affiliate counterparty

PDF Image20-44 Letter Type: No-Action
Division: DMO, DCR
Regulation Parts: 2(h)(8)
Tags: Cleared Swaps, Clearing Requirement, DCO, Execution, Trade Execution, Trade Execution Requirement
Issuance Date:
Description:

No-action relief permitting an FCM clearing member to, in the event of a customer default, effect swap transactions pursuant to LCH’s default rules and procedures without executing such transactions on a SEF, exempt SEF, or DCM as required by the trade execution requirement.

PDF Image20-42 Letter Type: No-Action
Division: DCR, MPD
Regulation Parts: 2(h), 2(h)(1), 23.150 - 23.161, 50 Subpart A, 50.4
Tags: Clearing Requirement, Margin, Brexit, Legacy Swaps
Issuance Date:
Description:

No-action letter permitting market participants to transfer certain swaps to an affiliate without such swaps becoming subject to the Commission’s swap clearing requirement or uncleared swap margin requirements in relation to the end of Brexit transition period