CFTC Staff Letters
CFTC Staff Letters provides Letters from 2008 and later. For Letters published before 2008 visit the Letters Archive page.
| Description | |
|---|---|
 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 |
| 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 |