CFTC Staff Letters

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.

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.  

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.  

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.

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).

Commission Regulation 1.17 – Staff no-action position regarding the treatment of operating leases caused by a change in accounting principles.

Exemptive relief granted to a CPO to permit the CPO to provide monthly account statements to participants within 45 days of the month end rather than quarterly account statement within 30 days of the quarter end pursuant to Commission regulation 4.7(b)(2).

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.

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.

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.