Interpretation of the Commodity Exchange Act and Commission regulations regarding the characterization of variation margin payments and all other cash flows for cleared swaps.

DSIO’s interpretation of Regulation 23.451 clarifying staff’s view that a swap dealer’s contributions for transition or inaugural expenses incurred by a successful candidate are only covered by the rule to the extent that such expenses are incurred by a successful candidate for a position as an official of a governmental Special Entity.

Interpretation of CFTC regulations 39.11(e)(1); 39.13(g)(10); 39.15(c) and (e); and 39.36(f) in light of amendments to Securities and Exchange Commission rule 2a-7.

Interpretative relief granted that states that a pool that is only funded and traded by two brothers is not a commodity pool

DCR and DMO Interpretation regarding use by a derivatives clearing organization of a firm or forced trades process. Request for Interpretation Regarding the Applicability of Commission Regulation 37.3(a)(1) and Section 2(h)(8) of the Commodity Exchange Act to Derivatives Clearing Organizations and their Clearing Members.

The CFTC Division of Clearing and Risk (the Division) interprets Part 39 (subparts A, B and C) to incorporate all of the standards set forth in the PFMIs and, indeed, to be fully consistent with the PFMIs. This position is supported by CFTC Regulation 39.40, which states that [t]his subpart C is intended to establish standards which, together with subparts A and B of this part [Part 39 of CFTC regulations], are consistent with Section 5b(c) of the Act and the Principles for Financial Market Infrastructures… and should be interpreted in that context.

The Division of Clearing and Risk published a letter interpreting Section 2(h)(7)(C)(iii) of the Commodity Exchange Act.

Interpretation with respect to certain auditor independence requirements under Commission Regulation 1.16.

No-action relief and interpretation of certain aspects of Regulation 30.7 with respect to the holding of customer funds in accounts located outside of the U.S.

Staff interpretation regarding notification of the right to segregation of initial margin in uncleared swap transactions and quarterly reporting under Commission Regulations 23.701 and 23.704