CFTC Staff Letters
CFTC Staff Letters provides Letters from 2008 and later. For Letters published before 2008 visit the Letters Archive page.
| Description | |
|---|---|
 25-18 |
Letter Type: No-Action Division: DMO Regulation Parts: 45 Tags: Recordkeeping, Reporting, Swap Data Issuance Date: Description: Extension of no-action position with respect to Part 45 for entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating consistent with CFTC exemptive orders or no-action positions provided by CFTC staff. See also: Request Letter Requester(s): ISDA |
| 25-17 |
Letter Type: No-Action Division: DMO Regulation Parts: 1.38, 38.500, 40.4, 40.6 Tags: Block Trades, DCM, Execution, DCM Core Principle 9, Part 40 Issuance Date: Description: After considering the request of MIAX Futures and related facts and circumstances, the Division believes that temporary no-action positions are warranted to provide participants in the HRSW Options market with a means to trade out of or offset their open positions in the September 2025 and December 2025 expirations when electronic trading is no longer available. Accordingly, the Division will not recommend that the Commission take an enforcement action against MIAX Futures in connection with the implementation of the Temporary HRSW Options Block Trading Protocol under DCM Core Principle 9 and Commission regulation 1.38. Further, the Division will not recommend that the Commission take an enforcement action against MIAX Futures under CEA section 5c(c) of the Act and associated Commission regulations under Part 40 if MIAX Futures amends its rulebook to implement the Temporary HRSW Options Block Trading Protocol before June 30, 2025, when an electronic trading system will no longer be available for the HRSW Options. See also: Request Letter Requester(s): MIAX |
| 25-16 |
Letter Type: No-Action Division: DMO Regulation Parts: 45, 46 Tags: Foreign, Foreign Transactions, MSP, Reporting, SD, Swap Dealer, Cross-border, Non-US Swap Dealers, Non-US MSP Issuance Date: Description: Extension of Time-Limited No-Action Position from Certain Requirements of Part 45 and Part 46 of the Commission’s Regulations, for Certain Swap Dealers and Major Swap Participants Established under the Laws of Australia, Canada, the European Union, Japan, Switzerland or the United Kingdom See also: Request Letter Requester(s): BAM, IIB, ISDA, SIFMA |
| 25-15 |
Letter Type: Advisories Division: DMO, DCR Regulation Parts: 38, 39 Tags: Issuance Date: Description: The Division of Market Oversight and the Division of Clearing and Risk are issuing this advisory to remind DCMs and DCOs of certain Core Principle and regulatory obligations under the Commodity Exchange Act and Commodity Futures Trading Commission regulations related to controls designed to address market volatility. Requester(s): CFTC |
| 25-14 |
Letter Type: Interpretative Division: MPD Regulation Parts: 3.10, 23, 30.1, 48.2 Tags: Foreign Future, Swaps, Cross-border, Foreign Boards of Trade Issuance Date: Description: The Commodity Futures Trading Commission’s Market Participants Division and Division of Market Oversight issued interpretative guidance confirming the application of certain cross-border definitions to SBC Limited. See also: Request Letter Requester(s): SCBL |
| 25-13 |
Letter Type: Advisories Division: DMO, DCR, MPD Regulation Parts: 23.602, 166.3 Tags: Compliance, Enforcement, Reporting, Self-Reporting, Cooperation, Remediation, Referral Criteria Issuance Date: Description: This staff advisory provides guidance on the materiality or other criteria that the Commodity Futures Trading Commission’s Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight will use to determine whether to make a referral to the Division of Enforcement (“DOE”) for self-reported violations, or supervision or non-compliance issues. This guidance furthers the implementation of DOE’s recent advisory, issued February 25, 2025, addressing its updated policy on self-reporting, cooperation, and remediation. Requester(s): CFTC |
| 25-12 |
Letter Type: No-Action Division: DCR, MPD Regulation Parts: 23.150 - 23.161, 50.2, 50.4 Tags: Issuance Date: Description: No-action positions in relation to the Commission’s swap clearing and uncleared swap margin requirements in connection with a court-supervised transfer, pursuant to the laws of the United Kingdom, of certain legacy swaps from Credit Suisse International to UBS AG London Branch following the merger of UBS Group AG and Credit Suisse Group AG. See also: Request Letter Requester(s): UBSAG |
| 25-11 |
Letter Type: Interpretative Division: MPD Regulation Parts: 23.156 Tags: Issuance Date: Description: UST ETFs that fall within the scope of the regulatory framework set forth in SEC Rule 6c-11 may qualify as eligible IM collateral as defined in the CFTC Margin Rule, provided the funds meet the criteria listed in Commission Regulation 23.156(a)(1)(ix). CSEs may collect or post UST ETFs that qualify as IM under Commission Regulation 23.156(a)(1)(ix) as VM for uncleared swap transactions with financial end users consistent with Commission Regulation 23.156(b)(1)(ii). See also: Request Letter Requester(s): GMAC |
| 25-10 |
Letter Type: Interpretative Division: DMO, MPD Regulation Parts: 1.3 Tags: Swap, Window FX Forwards, FX Spot Transactions, foreign exchange forwards, Foreign exchange spot transactions Issuance Date: Description: Joint MPD and DMO interpretation providing the Divisions’ views on the characterization of certain FX transactions as being swaps, foreign exchange forwards, or foreign exchange swaps, in each case, as defined in the Commodity Exchange Act and Commission Regulations. Specifically, the Divisions state their view that: Window FX Forwards, as described in the letter, should be considered to be “foreign exchange forwards;” and Package FX Spot Transactions, as described in the letter, should not be considered to be foreign exchange swaps or swaps. Requester(s): CFTC |
| 25-09 |
Letter Type: No-Action Division: MPD Regulation Parts: 23.431 Tags: Disclosures, Recordkeeping, Reporting, Requirements Issuance Date: Description: No-action position for swap dealers and major swap participants relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission Regulation 23.431(a)(3)(i). See also: Request Letter Requester(s): IIB, ISDA, SIFMA |