No-action position for registered swap dealers and major swap participants that enter into certain swaps referencing the Secured Overnight Financing Rate (described in the letter) relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission regulation 23.431(a)(3)(i).
Advisory to FCMs and time-limited no-action relief to DCOs with respect to the treatment of separate accounts by FCMs.
No-Action Position for Off-SEF Swaps Executed Pursuant to Prime Brokerage Arrangements
Exemptive relief that was provided in CFTC Staff Letters 14-35 and 14-36 with respect to the requirements of Commission regulations 4.21, 4.22, and 4.25 was extended to the successor CPO of the trusts and series in those letters, subject to certain conditions, including the following: (1) the material business terms of the trusts and series do not change; (2) the investment experience of the shareholders does not change; (3) the only material change is the substitution of the CPO; (4) the representations made by the CPO in CFTC Letters 14-35 and 14-36 remain applicable; and (5) the successo
No-Action Relief is provided to swap dealers from compliance with certain Commission regulations related to business conduct standards with counterparties and swap trading relationship documentation when entering into swaps with certain special purpose vehicles in existence prior to October 10, 2013.
The CPO of a commodity pool organized as a Delaware statutory trust requested relief to provide investors with disclosure documents for certain of the series of the trust separate from the disclosure document for the rest of the trust’s series due to compliance requirements pursuant to securities laws and regulations. The Division granted exemptive relief.
The CPO of a commodity pool organized as a Delaware statutory trust requested relief to provide investors with disclosure documents for certain of the series of the trust separate from the disclosure document for the rest of the trust’s series due to compliance requirements pursuant to securities laws and regulations. The Division granted exemptive relief.
The Division of Swap Dealer and Intermediary Oversight granted exemptive relief from the financial statement requirements of Commission regulations 4.22 and the disclosure requirements of Commission regulation 4.24(s) to the commodity pool operator (the “CPO”) of an insurance-linked securitization vehicle (the “ILS Vehicle”) with respect to the ILS Vehicle; provided, that the CPO satisfies certain conditions for relief relating to the management of the ILS Vehicle, the disclosure of additional information concerning the ILS Vehicle, and the calculation of the net asset value of the ILS Vehi
The Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter that provides relief for certain regulatory obligations of SDs and MSPs in the context of an “Intended-To-Be-Cleared Swap,” which, as defined in the letter, is a swap that is: (i) of a type accepted for clearing by a DCO, and (ii) intended to be submitted for clearing contemporaneously with execution. The relief extends to certain requirements under the External BCS and Commission Regulation 23.504, subject to the conditions and limitations set forth in the letter. This letter supersedes Letter No.
No-Action Relief: Swaps Intended to be Cleared - Request for relief from certain disclosure and notice requirements and other duties imposed on swap dealers (SDs) and major swap participants (MSPs) pursuant to Commission regulations 23.402, 23.430, 23.431, 23.432, 23.434, 23.440, 23.450, and 23.451, as well as certain documentation requirements imposed on SDs and MSPs pursuant to Commission regulation 23.504.
