CFTC Staff Letters

Advisory clarifying that no documentation concerning the collection, posting and custody of initial margin is required to be completed until the initial margin threshold amount of $50 million has been exceeded.

No-action relief from specified Part 39 regulations applicable to derivatives clearing organizations due to Eris Clearing, LLC’s fully-collateralized clearing model.

No-Action relief granted to registered floor traders from compliance with certain conditions in paragraph (6)(iv) of the "swap dealer" definition in CFTC regulation 1.3.

No-action relief granted to swap dealers from the uncleared swap margin requirements under Part 23 of the Commission's regulations with respect to certain amendments to legacy swaps.

No-action relief granted to a general partner of a SPE from CPO registration under CEA section 4m(1).

No-action relief was granted to an entity from the requirement to register as a CPO with respect to a commodity pool; provided that, the entity delegates its CPO responsibilities for that pool to a registered CPO, subject to certain conditions.

No-action relief granted to an entity for its branch from registration as an IB pursuant to CEA Section 4d(g) to provide sufficient time for the Commission to review the entity’s 30.10 Petition, subject to certain conditions.

This staff letter ensures that existing regulatory relief provided by DSIO, DMO, and DCR pursuant to certain existing staff letters affecting EU entities continues to be available for UK entities following Brexit.

No-action relief granted to ensure the continued availability, following Brexit, of regulatory relief under certain existing CFTC comparability determinations and exemption orders originally issued by the CFTC for EU entities, while CFTC staff undertakes an analysis of UK law in order to make appropriate recommendations of comparability or exemption to the CFTC.

Granting time-limited no-action relief to [“A”] permitting its Irish bank subsidiary, [“B”], to act as reporting counterparty for [“B”]’s swaps with U.S. persons that are not swap dealers (“SDs”) or major swap participants (“MSPs”), notwithstanding the allocation of reporting responsibility set forth in Commission Regulation 45.8(e).