CFTC Staff Letters

Time-Limited No-Action Relief for Certain Members of Swap Execution Facilities and Designated Contract Markets from the Requirement to Record Oral Communications, Pursuant to Commission Regulation 1.35(a), in Connection with the Execution of Swap Transactions

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing and certification requirements in Regulations 4.7(b)(3) and 4.22(d) for fiscal year 2013 due to the pool’s ongoing significant exposure to an FCM bankruptcy and permission to file uncertified annual reports in lieu thereof.

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing and certification requirements in Regulations 4.22(c) and 4.22(d) for fiscal year 2013 and permission to file uncertified annual reports in lieu thereof and attached a waiver from the non-proprietary participant.

The investment manager of a cash collateralized loan obligation (CLO) transaction requested, and DSIO granted pursuant to Regulation 140.99, a no action position from DSIO that it would not recommend that the Commission commence an enforcement action for its failure to register as a commodity trading advisor with respect to the advice provided to the CLO.

The CPOs of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing requirements in Regulation 4.22(c) for fiscal year 2013 and requested to be permitted to file with NFA and distribute to participants an annual report for the pool covering the period from January 1, 2013 to March 7, 2014, when the pool permanently ceased trading.

No-action relief regarding format of acknowledgment letters and format and content of daily reports for DCO winding down operations in anticipation of vacating its DCO registration.

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing and certification requirements in Regulations 4.7(b)(3) and 4.22(d). The CPO requested permission to file an uncertified annual report for fiscal year 2013.

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing and certification requirements in Regulations 4.7(b)(3) and 4.22(d) for fiscal year 2013.

The CPOs of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing requirements in Regulation 4.22(c) for fiscal year 2013 and requested to be permitted to file with NFA and distribute to participants an annual report for the pool covering the period from January 1, 2013 to March 24, 2014, when the pool permanently ceased trading.

The CPO of a commodity pool requested, and DSIO granted pursuant to Regulations 4.12(a) and 140.93, relief from the Annual Report filing and certification requirements in Regulations 4.7(b)(3) and 4.22(d) and permission to distribute and file a 15-month annual report covering the period from inception of trading on October 1, 2013 through December 31, 2014.