CFTC Staff Letters
CFTC Staff Letters provides Letters from 2008 and later. For Letters published before 2008 visit the Letters Archive page.
| Description | |
|---|---|
 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 |
| 25-45 |
Letter Type: No-Action Division: DMO, DCR Regulation Parts: 38.8, 38.10, 38.951, 39.20, 43, 45 Tags: Reporting, Swap, Swap Data, Swaps, Event Contract, Part 43, Binary Option, Part 45 Issuance Date: Description: Modification of no-action position with respect to Part 43 and 45 reporting, as well as related sections of Parts 38 and 39, for binary options executed on or pursuant to the rules of MIAXdx and cleared through MIAXdx. See also: Request Letter Requester(s): LEDGERX |
| 25-44 |
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: No-action position with respect to Part 43 and 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 Gemini Titan LLC and cleared through QC Clearing LLC. See also: Request Letter Requester(s): GEM, QCCLEAR |
| 25-43 |
Letter Type: No-Action Division: DMO Regulation Parts: 43, 43.3, 45, 45.14 Tags: Real-Time, Reporting, Swap Data, Part 43, Part 45 Issuance Date: Description: The Division of Market Oversight (“DMO”) of the Commodity Futures Trading Commission (“CFTC” or “Commission”) is issuing this letter in response to a request (the “Request”) from the International Swaps and Derivatives Association (“ISDA”) pursuant to Commission regulation 140.99. ISDA requests the Division issue a letter providing a no-action position with respect to certain requirements in Commission regulations 43.3(e) and 45.14(a), which generally require reporting counterparties to correct errors in swap transaction and pricing data and swap data submitted to swap data repositories (“SDRs”). See also: Request Letter Requester(s): ISDA |
| 25-42 |
Letter Type: No-Action Division: DMO, DCR, MPD Regulation Parts: 2(a), 2(h), 2(h)(1), 2(h)(8), 23, 23.160, 43, 45, 46, 50 Tags: Margin, Swap, Swap Dealer, External Business Conduct, Uncleared Swaps, Business Conduct Standards, Documentation, Cross-border Issuance Date: Description: No-action position on using the definitions of the terms “U.S. person” and “guarantee” in Commission Regulation 23.23 to classify counterparties across the Commission’s cross-border swaps framework and on the continued reliance on the use of prior representations in doing so. See also: Request Letter Requester(s): IIB, ISDA, SIFMA |
| 25-41 |
Letter Type: Advisories Division: MPD Regulation Parts: 4d, 4d(f) Tags: FCM, Customer Funds Issuance Date: Description: Withdrawal of CFTC Staff Advisory 20-34 on Accepting Virtual Currencies from Customers into Segregation. See also: Request Letter Requester(s): CFM |
| 25-40 |
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. See also: Request Letter Requester(s): CFM |
| 25-39 |
Letter Type: Advisories Division: MPD, DCR, DMO Regulation Parts: 1, 1.11, 23.156, 23.600, 39, 39.13 Tags: Collateral, Margin, Risk Management, Digital Assets Issuance Date: Description: The Market Participants Division (“MPD”), Division of Market Oversight (“DMO”), and Division of Clearing and Risk (“DCR” and, together with MPD and DMO, the “Divisions”) of the Commodity Futures Trading Commission are issuing this guidance to provide the Divisions’ views on the use of tokenized assets as collateral in the trading of futures and swaps. Requester(s): CFTC |