CFTC Staff Letters

CFTC Staff Letters provides Letters from 2008 and later. For Letters published before 2008 visit the Letters Archive page.

PDF Description
PDF Image 12-78 Letter Type: No-Action
Division: DSIO
Regulation Parts: 43, 45, 46
Tags: Public, Real-Time, Recordkeeping, Reporting, Swap Data, Transition Swaps
Issuance Date:
Description:

The Division of Market Oversight issued time-limited, no-action relief to Deutsche Bank with respect to various reporting requirements under Parts 43, 45, and 46 that Deutsche Bank was required to comply with as of December 31, 2012.


PDF Image 12-72 Letter Type: No-Action
Division: DSIO
Regulation Parts: 4m(1), 4.5, 4.6
Tags: CPO, CTA, Exclusion, Interstate
Issuance Date:
Description:

The Division of Swap Dealer and Intermediary Oversight took a CPO and CTA registration no-action position with respect to a registered investment adviser that acted as the sponsor and investment manager for a pension plan group trust. Each of the plans participating in the group trust was within the categories of plans excluded under Regulation 4.5 from the “pool” definition.


PDF Image 12-71 Letter Type: No-Action
Division: DSIO
Regulation Parts: 1.3(ggg)(4)
Tags: De Minimis, Exception, Swap Dealer
Issuance Date:
Description:

No-Action Relief: U.S. Bank Wholly Owned by Foreign Entity May Calculate De Minimis Threshold Without Including Activity From Its Foreign Affiliates.


PDF Image 12-70 Letter Type: No-Action, Interpretative
Division: DSIO
Regulation Parts: 4d, 4m
Tags: CPO, CTA, FCM, IB, Interstate, Unregistered
Issuance Date:
Description:

Relief for Certain Swap Dealers, De Minimis Dealers, Agent Affiliates, and Associated Persons from Registration as an Introducing Broker under Section 4d or a Commodity Trading Advisor under Section 4m of the Commodity Exchange Act, and Interpretation that Certain Employees of De Minimis Dealers are not an Introducing Broker as defined in Section 1a(31) of the Commodity Exchange Act.


PDF Image 12-69 Letter Type: No-Action
Division: DSIO
Regulation Parts: 4d, 4e, 4m, 4s(b)(6)
Tags: CPO, CTA, FCM, IB, Interstate, MSP, Registration, SD, Unregistered
Issuance Date:
Description:

Extension of Temporary Registration Relief under CFTC Staff Letter No. 12-15 for Certain Associated Persons.


PDF Image 12-68 Letter Type: No-Action
Division: DSIO
Regulation Parts: 4.5, 4.13
Tags: CPO, Exclusion, Exemption, Registration
Issuance Date:
Description:

Temporary Registration Relief for Commodity Pool Operators and Commodity Trading Advisors that Must Register as a Result of Amended CFTC Regulation 4.5 and Rescinded CFTC Regulation 4.13(a)(4).


PDF Image 12-67 Letter Type: No-Action
Division: DSIO
Regulation Parts: 3, 4
Tags: CPO, CTA, Registration
Issuance Date:
Description:

No-Action Relief for Investment Pools Investing in Certain Securitization Vehicles Formed Prior to October 12, 2012.


PDF Image 12-62 Letter Type: No-Action
Division: DSIO
Regulation Parts: 1.3(ggg)(4)
Tags: De Minimis, Exception, Swap Dealer
Issuance Date:
Description:

No-Action Relief: Request that Certain Swaps Not Be Considered in Calculating Aggregate Gross Notional Amount for Purposes of the Swap Dealer De Minimis Exception for Persons Engaging in Multilateral Portfolio Compression Activities.


PDF Image 12-61 Letter Type: No-Action
Division: DSIO
Regulation Parts: 1.3(ggg)(4)
Tags: De Minimis, Exception, Swap Dealer
Issuance Date:
Description:

No-Action Relief: U.S. Bank Wholly Owned by Foreign Entity May Calculate De Minimis Threshold Without Including Activity From Its Foreign Affiliates.


PDF Image 12-60 Letter Type: No-Action
Division: DSIO
Regulation Parts: 1.3(ggg)(4)
Tags: De Minimis, Exception, Swap Dealer
Issuance Date:
Description:

Time-Limited No-Action Relief: Request that Certain Swaps Not Be Considered in Calculating Aggregate Gross Notional Amount for Purposes of the Swap Dealer De Minimis Exception for Persons Engaging in Floor Trader Activities. (Extended 13-37)