Letters

Date Title
18-19 PDF Image; Commission Regulation 1.17; No-Action
Commission Regulation 1.17 – Staff no-action position regarding the treatment of operating leases caused by a change in accounting principles.
18-18 PDF Image; CEA Section 5b(a) and the Commission regulations thereunder; No-Action
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.
18-13 PDF Image; Sections 1a(33)(B) and 1a(49)(D) of the Commodity Exchange Act and CFTC Regulation 1.3; No-Action
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.  
18-15 PDF Image; CEA Section 4m(1); No-Action
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.
18-16 PDF Image; CEA Section 4m(1); No-Action
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.
18-08 PDF Image; CEA Section 4m(1), Regulations 4.5 and 4.6;; No-Action
The Division of Swap Dealer and Intermediary Oversight provided no-action relief from CPO and CTA registration to the trustee of a pension plan group trust comprised solely of pension plans that are “not construed to be pools” under Regulation 4.5(a)(4)(i)-(iii).
18-04 PDF Image; CEA Section 5b(a) and the Commission regulations thereunder; No-Action
No-Action 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.
18-03 PDF Image; Sections 45.3, 45.4, 45.5, and Appendix 1 of Part 45; No-Action
No-Action Extension of no-action relief originally granted by DMO on December 19, 2016 to counterparties clearing swaps through derivatives clearing organizations acting under exemptive or no-action relief from certain reporting obligations for cleared swaps under Part 45 of the Commission's regulations.
18-02 PDF Image; Sections 4d(g) and 4k of the Commodity Exchange Act; CFTC Regulations 3.4(a) and 3.12(a); No-Action
No-Action  CFTC staff issues time limited no-action relief to Shorcan Energy Brokers Inc. and its associated persons for introducing broker and associated person registration.
18-01 PDF Image; Commission Regulation 1.17;; No-Action
Staff no-action position regarding the treatment of a deferred tax liability caused by a change in accounting principles.