Letters

Date Title
18-27 PDF Image; CEA Section 4a; CFTC § 150.4; No-Action
This no-action letter provides relief from compliance with certain position aggregation requirements under Commission Regulation 150.4.   
18-26 PDF Image; Commission Regulation 30.7; No-Action
Commission Regulation 30.7 – Staff No-Action Position Regarding Futures Commission Merchant’s Deposit of Customer-Owned Securities as Margin with a Foreign Broker.  
18-21 PDF Image; Commission Regulation 1.16; No-Action
Commission Regulation 1.16 – Staff no-action position regarding compliance with Public Company Accounting Oversight Board requirement to communicate “critical audit matters” in Accountants’ Unqualified Audit Opinions.
18-20 PDF Image; CEA section 1a(49); Regulation 1.3, paragraph 4 of “swap dealer” definition; No-Action
Conditional, time-limited no-action relief to an entity for not counting certain loan-related swaps towards its swap dealer de minimis threshold (under paragraph (4) of the “swap dealer” definition in Regulation 1.3).
18-24 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity (Ltd.) from registering as a CPO with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.
18-23 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity (LLC) from registering as a CPO with respect to certain commodity pools; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.  
18-22 PDF Image; Commodity Exchange Act section 4m(1); No-Action
No-action relief granted to an entity from registering as a CPO with respect to a commodity pool; provided, that it delegates its CPO responsibilities to a registered CPO, subject to certain conditions.  
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.