CFTC Staff Letters

No-action relief granted to an entity (Ltd.) from registering as a CPO with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.

No-action relief granted to an entity (LLC) from registering as a CPO with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.  

No-action relief granted to an entity from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.  

Commission Regulation 1.16 – Staff no-action position regarding compliance with Public Company Accounting Oversight Board requirement to communicate “critical audit matters” in Accountants’ Unqualified Audit Opinions.

Conditional, time-limited no-action relief to an entity for not counting certain loan-related swaps towards its swap dealer de minimis threshold (under paragraph (4) of the “swap dealer” definition in Regulation 1.3).

Commission Regulation 1.17 – Staff no-action position regarding the treatment of operating leases caused by a change in accounting principles.

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.

No-action relief granted to an entity from CPO registration with respect to a commodity pool for which it serves as trustee; provided, that it delegates the CPO responsibilities to a registered CPO, subject to certain conditions.

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.

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.