Accordingly, the conditional no-action position with respect to Regulation 39.13(g)(8)(iii) contained in CFTC Letter No. 19-17 is now further extended until the earlier of (a) June 30, 2025 or (b) the effective date of any final Commission action relating to the Second Proposal.

Advisory to SDs indicating they are not required to obtain approval to use a model to calculate the initial margin on uncleared swaps for purposes of determining the SD’s minimum capital requirement under Commission regulations.

Staff no-action position regarding the treatment of a deferred tax liability under Regulation 1.17 which is directly related to intangible assets booked as a result of an acquisition.

No-action positions for futures commission merchants and introducing brokers to address net capital treatment of covered loans under the CARES Act in response to the COVID-19 pandemic.

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

Staff no-action position regarding the treatment of a deferred tax liability caused by a change in accounting principles.

Request for No-Action Relief for Introducing Brokers’ Compliance with Certain Financial Reporting and Capital Computation Requirements under Regulations 1.10 and 1.17.

Staff issued an interpretation providing that a futures commission merchant (FCM) may credit a customer’s trading account for a margin payment upon the FCM’s initiation of a withdrawal from the customer’s bank account using the Automated Clearing House (ACH) payment processing system. The FCM also may consider such pending margin payments in computing its regulatory capital.

No-action relief for certain Introducing Brokers from filing certified and unaudited financial statements and calculating capital under regulation 1.17.