CFTC Staff Letters

No-action relief granted to a swap dealer concerning the calculation of initial margin under Commission regulation 23.154.

No-action relief to facilitate an orderly transition of swaps from inter-bank offered rates to alternative benchmarks.

Staff Time-Limited No-Action Position Regarding Application of Minimum Transfer Amount under the Uncleared Margin Rules

Advisory providing further guidance on certain requirements applicable to swap dealers, futures commission merchants, and major swap participants in connection with the preparation and submission of chief compliance officer annual compliance reports pursuant to § 3.3.

Revised no-action position with respect to uncleared swaps with the European Stability Mechanism under Commission Regulations 23.150-159, 23.161.

No-action relief was granted to an entity from the statutory disqualification condition of CFTC Staff Letter No. 12-70 with repsect to its affiliate support activities.

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.

The guidance clarifies the CIP and BO requirements applicable to introducing brokers (IBs) under the Bank Secrecy Act (BSA). The guidance provides regulatory clarity to certain IBs who lack access to the information needed to comply with CIP and BO obligations. The guidance eliminates duplicative efforts without impacting money laundering or terrorist financing risk, as the customer due diligence obligations will continue to be performed by the futures commission merchant (FCM) that carries the customer account. The particular IBs subject to this guidance do not introduce their customers’ accounts to FCMs. The IBs do not receive or have access to the customer identification and financial information obtained by FCMs, or the monthly account information issued by FCMs. This guidance clarifies that these IBs are not required to carry out CIP and comply with BO requirements.

Advisory to FCMs and time-limited no-action relief to DCOs with respect to the treatment of separate accounts by FCMs.

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.