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Currently Effective Staff Letters
Publication Date | Letters |
11/26/2015 | CFTC’s Division of Market Oversight issues time-limited no-action relief from certain requirements of Part 45 and Part 46 of the Commission’s regulations, for Certain Swap Dealers and Major Swap Participants established under the laws of Australia, Canada, the European Union, Japan and Switzerland. |
06/04/2014 | Extension of No-Action Relief: Transaction-Level Requirements for Non-U.S. Swap Dealers. |
02/10/2014 | No-Action Relief from the Commodity Exchange Act Sections 2(h)(8) and 5(d)(9) and from Commission Regulation 37.9 for Swaps Executed as Part of a Package Transaction. |
01/03/2014 | Extension of No-Action Relief: Transaction-Level Requirements for Non-U.S. Swap Dealers |
12/31/2013 | The CFTC’s Division of Market Oversight has issued a no-action letter in connection with certain CDS trades executed pursuant to a DCO’s CDS Settlement Price Process, providing time-limited no-action relief to DCOs and their Clearing Members from the SEF Registration Requirement and Trading Mandate under Part 37, and from various reporting requirements under Part 45, allowing the DCO to fulfill the Reporting Counterparty’s Obligations. |
12/30/2013 | Time-Limited No-Action Relief for Certain Swap Dealers from Compliance with the Requirements of Commission Regulation 3.3 Relating to Annual Reports by Chief Compliance Officers. |
12/23/2013 | The CFTC’s Division of Market Oversight has issued a no-action letter providing relief to swap execution facilities (SEFs) that provide basis risk mitigation services for required transactions for failure to comply with the execution methods required under Part 37.9(a)(2) of the Commission’s regulations. |
12/20/2013 | Time-Limited No-Action Letter from Certain Entity-Level Internal Business Conduct Requirements for Certain Swap Dealers and Major Swap Participants Established under the Laws of Australia, Canada, the European Union, Japan, and Switzerland. |
12/20/2013 | Conditional Time-Limited No-Action Relief for Yieldbroker Pty Ltd with Regard to Section 5h(a)(1) of the Commodity Exchange Act and Commission Regulation 37.3(a)(1). |
12/20/2013 | CFTC’s Division of Market Oversight Issues Time-Limited No-Action Relief from Certain Requirements of Part 45 and Part 46 of the Commission’s Regulations, for Certain Swap Dealers and Major Swap Participants Established under the Laws of Australia, Canada, the European Union, Japan or Switzerland. |
12/19/2013 | Extension of a Time-Limited No-Action Relief to Japan Securities Clearing Corporation and Its Qualifying Participants and Affiliates concerning Sections 5b(a) and 2(h)(1)(A) of the Commodity Exchange Act. |
11/26/2013 | Time-limited no-action relief for Non-U.S. SDs with respect to compliance with Transaction-Level Requirements when entering into Covered Transactions, until January 14, 2014. |
11/01/2013 | CFTC’s Division of Market Oversight Issues Extension of Certain Time-Limited No-Action Relief Regarding Swap Execution Facilities Provided by CFTC No-Action Letter Nos. 13-55 (amended), 13-56 and 13-58 for Swaps in the Foreign Exchange Asset Class. |
10/17/2013 | Time-Limited No-Action Relief for GTX SEF LLC from the Registration Requirements of Section 5h(a)(1) of the Commodity Exchange Act and Commission Regulation 37.3(a)(1). |
10/17/2013 | Time-Limited No-Action Relief for LatAm SEF, LLC from the Registration Requirements of Section 5h(a)(1) of the Commodity Exchange Act and Commission Regulation 37.3(a)(1). |
09/30/2013 | Time-Limited No-Action Relief for (1) Futures Commission Merchants from Requirement to Comply with Commission Regulations 1.73(a)(2)(i) and (a)(2)(ii); and (2) Temporarily Registered Swap Execution Facilities from Requirement to Comply with Commission Regulation 37.702(b).. Rules 1.73(a)(2)(i)-(ii), 37.702(b); No-Action |
09/30/2013 | Time-Limited No-Action Relief: Request that Certain Swaps Not Be Considered in Calculating Aggregate Gross Notional Amount for Purposes of the Swap Dealer De Minimis Exception for Persons Engaging in Floor Trader Activities. This letter extends the time-limited relief previously provided by DSIO in CFTC Letter Nos. 13-37 and 12-60. |
09/30/2013 | Time-Limited No-Action Relief for Swap Execution Facilities and Designated Contract Markets from the One Business Day Product Review Period Requirement of Commission Regulation 40.2(a)(2) for Newly-Listed Swap Products. Commission regulation 40.2(a)(2); No-Action |
09/30/2013 | Time-Limited No-Action Relief for Yieldbroker Pty Limited with Regard to Section 5h(a)(1) of the Commodity Exchange Act and Commission Regulation 37.3(a)(1). CEA section 5h(a)(1); Commission Regulation 37.3(a)(1); No-Action |
09/30/2013 | Time-Limited No-Action Relief to Temporarily Registered Swap Execution Facilities from Commission Regulation 37.6(b) for Non-Cleared Swaps in All Asset Classes. 37.6(b); No-Action |
09/27/2013 | Time-Limited No-Action Relief for Temporarily Registered Swap Execution Facilities from Enforcement Responsibilities Under Commission Regulations 37.200(a), 37.200(b), 37.201(b)(1), 37.201(b)(3), 37.201(b)(5), 37.202(b) and 37.203 with respect to market participants trading on those SEFs. Commission Regulations 37.200(a), 37.200(b), 37.201(b)(1), 37.201(b)(3), 37.201(b)(5), 37.202(b) and 37.203; No-Action; September 27, 2013 |
09/27/2013 | Time Limited No-Action Relief for Reporting Counterparties from Certain Continuation Data Reporting Requirements of Section 45.4 of the Commission’s Regulations with respect to Uncleared Swaps Executed on or Pursuant to the Rules of a Temporarily Registered Swap Execution Facility. |
09/27/2013 | Swap Data Reporting Requirements of Parts 43 and 45 of the Commission’s Regulations. |
09/27/2013 | No-Action Relief for Nodal Exchange, LLC with Regard to Commission Regulation 40.2(a)(2). |
09/27/2013 | No-Action Relief for LCH.Clearnet Ltd with Regard to Clearing Futures and Options on Futures Executed on Nodal Exchange. |
08/23/2013 | The Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter stating that the Division will not recommend that the Commission take an enforcement action against an SD or MSP for failure to comply, prior to September 15, 2013, with Regulation 23.502, provided that the SD or MSP intends to rely upon – and be compliant with – the EMIR portfolio reconciliation rules, beginning on September 15, 2013, and otherwise satisfies the conditions set forth in CFTC Letter No. 13-45 Corrected. |
07/11/2013 | No-Action Relief for Eurex Clearing AG with Regard to Sections 5b(a) and 2(h)(1)(A) of the Commodity Exchange Act and Implementing Regulations Thereunder..
Please see Attachment A-Products Offered for Clearing by Eurex Clearing AG |
07/11/2013 | No-Action Relief for LCH.Clearnet with Regard to Sections 5b(a) and 2(h)(1)(A) of the Commodity Exchange Act and Implementing Regulations Thereunder. |
06/27/2013 | The Division of Swap Dealer and Intermediary Oversight issued a time-limited no-action letter that grants relief to all swap dealers and major swap participants from the portfolio reconciliation requirements of Regulation 23.502 until August 23, 2013. |
06/27/2013 | The Division of Swap Dealer and Intermediary Oversight issued a no-action letter that provides swap dealers with relief from certain External Business Conduct Standards rules in the context of foreign exchange intermediated prime brokerage arrangements. |
06/27/2013 | Time-Limited No-Action Relief Regarding Certain Documentation Requirements for Swap Dealers (“SDs”) and Major Swap Participants (“MSPs”) with Foreign Exchange Counterparties. |
06/27/2013 | Time-Limited No-Action Relief: Request that Certain Swaps Not Be Considered in Calculating Aggregate Gross Notional Amount for Purposes of the Swap Dealer (“SD”) De Minimis Exception for Persons Engaging in Floor Trader Activities. |
06/27/2013 | Extension of Time-Limited No-Action Relief for Swap Dealers and Major Swap Participants from the Reporting Requirements of Part 45 for CDS Clearing-Related Swaps. |
06/27/2013 | Additional Time-Limited No-Action Relief for Bespoke or Complex Swaps from Certain Swap Data Reporting Requirements of Parts 43 and 45 of the Commission’s Regulations. |
06/26/2013 | Extension of Time-Limited No-Action Relief for Swap Dealers and Major Swap Participants from Compliance with Reporting Obligations Under 17 CFR § 45.4(b)(2)(ii). |
06/26/2013 | No-Action Relief: Swaps Intended to be Cleared. |
06/26/2013 | Request for Time-Limited No-Action Relief for Certain Swap Dealers from Compliance with Requirements of Commission Regulation 3.3 Relating to Annual Reports by Chief Compliance Officers. |
06/21/2013 | Extension of Time-Limited No-Action Relief from the Clearing Requirement for Swaps Entered into by Cooperatives. |
06/17/2013 | Staff No-Action Relief: Extension of the Regulatory Status Quo |
06/10/2013 | Time-Limited No-Action Relief for Certain Banks Having Assets of Less than $10 billion from the Board Approval Requirement of Section 2(j) of the CEA and the End-User Exception to the Clearing Requirement (§ 50.50(b)(1)(iii)(D)(2)). Section 2(j) of the Commodity Exchange Act and CFTC Regulation 50.50(b)(1)(iii)(D)(2); No-Action 13-26 |
06/07/2013 | Time-Limited No-Action Relief from the Clearing Requirement for Swaps Entered into by Cooperatives. |
06/04/2013 | No-Action Relief from the Required Clearing for Swaps Entered Into By Eligible Treasury Affiliates. |
05/31/2013 | No-action Relief: Extension for Compliance with Rule 1.73(a)(2)(v)(B) - Screening of Bunched Orders. |
05/02/2013 | Time-Limited Relief for Swap Dealers and Major Swap Participants from Compliance with Business Conduct Standards in Foreign Exchange Transactions with a Settlement Cycle of No More than Seven Local Business Days. |
04/09/2013 | Time-Limited No-Action Relief for Swap Counterparties that are not Swap Dealers or Major Swap Participants, from Certain Swap Data Reporting Requirements of Parts 43, 45 and 46 of the Commission’s Regulations. |
03/29/2013 | Time-Limited No-Action Relief for Securitization Vehicles Regarding Compliance with Part 4 of the Commission’s Regulations. Part 4 |
03/30/2013 | Request for No-Action Relief for Swap Dealers and Major Swap Participants from Compliance with Certain Internal Business Conduct Requirements Found in Subpart F to Part 23 of the CFTC’s Regulations Commission Regulations 23.201, 23.202, 23.203; No-Action 13-06 |
03/29/2013 | Extension of Staff No-Action Relief with Respect to Certain CEA Provisions That May Apply to Certain RTOs, ISOs, and/or Their Participants. Section 4(c)(6); No-Action 13-05 |
03/29/2013 | Relief for Additional Agent Affiliates from Registration as an Introducing Broker under Section 4d or a Commodity Trading Advisor under Section 4m of the Commodity Exchange Act. Sections 4d and 4m of the Commodity Exchange Act; No-Action 13-04 |
03/29/2013 | Extension for compliance with Regulation 39.12(b)(7) for LCH.Clearnet Limited for acceptance or rejection of trades submitted for clearing, until May 17, 2013. Regulation 39.12(b)(7); Extension Staff Letter |
03/28/2013 | No-Action Relief for Certain Futures Commission Merchants from Compliance with Certain Requirements of Commission Regulation 3.3 Relating to Annual Reports by Chief Compliance Officers. Commission Regulation 3.3; No-Action 13-03 |
12/28/2012 | Extension of Temporary Registration Relief under CFTC Staff Letter No. 12-15 for Certain Associated Persons. Section 4k of the Commodity Exchange Act and CFTC Regulation 3.12; No-Action 12-69 |
12/21/2012 | Temporary Registration Relief for Commodity Pool Operators and Commodity Trading Advisors that Must Register as a Result of Amended CFTC Regulation 4.5 and Rescinded CFTC Regulation 4.13(a)(4). Part 4 of the Commission’s Regulations; No-Action 12-68 |
12/21/2012 | No-Action Relief for Investment Pools Investing in Certain Securitization Vehicles Formed Prior to October 12, 2012. Parts 3 and 4 of the Commission’s Regulations; No-Action 12-67 |
12/21/2012 | Relief regarding the reporting of swap transaction data. Parts 43, 45 and 46; No-Action 12-66 |
12/21/2012 | Time-Limited No-Action Relief from the Reporting of Certain Non-Reporting Counterparty Information Pursuant to Parts 45 and 46 Part 45 and Part 46; No-Action 12-65 |
12/21/2012 | Time Limited No-Action Relief: Compo Equity Total Return Swaps. Mixed swaps, Section 1a(47)(D) of the Commodity Exchange Act; No-Action 12-64 |
12/21/2012 | No-Action Relief for Singapore Exchange Derivatives Clearing Limited with Regard to Section 5b(a) and Section 4d(f) of the Commodity Exchange Act. Sec. 5b(a) and Sec. 4d(f)(1) of the CEA; No-Action 12-63 |
12/20/2012 | No-Action Relief: U.S. Bank Wholly Owned by Foreign Entity May Calculate De Minimis Threshold Without Including Activity From Its Foreign Affiliates. Commission Regulation 1.3(ggg)(4); No-Action 12-61 |
12/19/2012 | Time-Limited No-Action Relief: Request that Certain Swaps Not Be Considered in Calculating Aggregate Gross Notional Amount for Purposes of the Swap Dealer De Minimis Exception for Persons Engaging in Floor Trader Activities. Commission Regulation 1.3(ggg); No-Action 12-60 |
12/19/2012 | Time-Limited No-Action Relief for Swap Dealers and Major Swap Participants from the Reporting Provisions of Part 45 for CDS Clearing-Related Swaps. Sections 2(a)(13)(G) and 21(b) of the Commodity Exchange Act, and part 45 of the CFTC regulations; No-Action 12-59 |
12/18/2012 | Time-Limited No-Action Relief: Request that Swaps Transacted on Natural Gas Exchange Not Be Considered in Calculating Aggregate Gross Notional Amount for Purposes of Swap Dealer De Minimis Exception. Commission Regulation 1.3(ggg); No-Action 12-57 |
12/17/2012 | No-Action Relief for Japan Securities Clearing Corporation with Regard to Section 5b(a) of the Commodity Exchange Act and Section 2(h)(1)(A) of the Commodity Exchange Act and Implementing Regulations Thereunder. Sections 5b(a) and 2(h)(1)(A) of the Commodity Exchange Act and Parts 39 and 50 of Commission Regulations; No-Action 12-56 |
12/17/2012 | Time-Limited No-Action Relief from (i) Parts 43 and 45 Reporting for Prime Brokerage Transactions, and (ii) Reporting of Unique Swap Identifiers in Related Trades under Part 45 by Prime Brokers Parts 43 and 45; No-Action 12-53 |
12/14/2012 | Request for Time-Limited No-Action Relief for Certain Swap Dealers from Compliance with Requirements of Commission Regulation 3.3 Relating to Annual Reports by Chief Compliance Officers. Commission Regulation 3.3; No-Action 12-52 |
12/14/2012 | Clarification of Division of Market Oversight No-Action Letter 12-04 (July 17, 2012), and Extension of No-Action Relief for Non-Clearing Member Swap Dealers from Large Swap Trader Reporting Requirements of Section 20.4 of the Commission’s Regulations. Part 20 of the CFTC’s regulations; No-Action 12-51 |
12/11/2012 | Staff No-Action Relief: Preservation of the Regulatory Status Quo Established with Respect to Certain Transactions by the Commission’s Second Amendment to July 14, 2011 Order for Swap Regulation. CEA Sections 2(d), 2(e), 2(g), 2(h), 5d;; No-Action 12-48 |
12/10/2012 | Request for Time-Limited No-Action Relief for Certain Futures Commission Merchants from Compliance with Certain Requirements of Commission Regulation 3.3 Relating to Annual Reports by Chief Compliance Officers. Regulation 3.3; No-Action 12-47 |
12/10/2012 | Time-Limited No-Action Relief for Swap Dealers and Major Swap Participants From Compliance With Reporting Obligations Under 17 CFR § 45.4(b)(2)(ii). Sections 2(a)(13)(G) and 21(b) of the Commodity Exchange Act, and § 45.4(b)(2)(ii) of the CFTC regulations; No-Action |
12/07/2012 | Time-limited no-action relief for Part 20 Reporting Entities regarding identifying information and for Part 45 and Part 46 Reporting Counterparties regarding legal entity identifiers and other identifying information. Part 20, Part 45 and Part 46; No-Action 12-46 |
12/07/2012 | No-Action Relief for Registered Swap Dealers and Major Swap Participants from Certain Requirements under Subpart I of Part 23 of Commission Regulations in Connection with Uncleared Swaps Subject to Risk Mitigation Techniques under EMIR. Parts 3 and 4 of the Commission’s Regulations; Section 1a(10) of the CEA; No-Action; Interpretation 12-45 |
12/05/2012 | No-Action Relief for Swap Dealers from Certain Swap Data Reporting Requirements of Part 43, Part 45 and Part 46 of the Commission’s Regulations Due to Effects of Hurricane Sandy. Part 43, Part 45 and Part 46 of the CFTC's regulations; No-Action 12-41 |
11/30/2012 | Time-Limited No-Action Relief for Bespoke or Complex Swaps from Certain Swap Data Reporting Requirements of Parts 43 and 45 of the Commission’s Regulations. Part 43 and Part 45: §§ 43.3(a); 43.4(a); Appendix A to Part 43; 45.3(b)(1); 45.3(b)(3); 45.3(c)(1)(i); 45.3(c)(1)(iii); 45.3(c)(2)(i); 45.3(c)(2)(iii); 45.3(d)(1); 45.3(d)(3); 45.4(c); and Appendix 1; No-Action 12-39 |
11/28/2012 | Time-Limited No-Action Relief from the Clearing Requirement for Swaps Entered Into By Cooperatives. Section 2(h) of the CEA; No-Action 12-36 |
11/28/2012 | Time-Limited No-Action Relief from the Clearing Requirement for Swaps Between Affiliated Counterparties. Section 2(h) of the CEA; No-Action 12-35 |
11/21/2012 | The Division of Clearing and Risk granted an extension for compliance with Regulation 39.12(b)(7) for LCH.Clearnet Limited for acceptance or rejection of trades submitted for clearing, until March 31, 2013. Regulation 39.12(b)(7); Extension Staff Letter |
11/19/2012 | Time-Limited No-Action Relief for Swap Dealers from Certain Swap Data Reporting Requirements of Part 43, Part 45 and Part 46 of the Commission’s Regulations. Part 43, Part 45 and Part 46 of the CFTC's regulations; No-Action 12-32 |
10/31/2012 | Staff No-Action Relief: Temporary Delay of Compliance Date for Part 22 Rules Due to Effects of Hurricane Sandy. Part 22; No-Action 12-30 |
10/26/2012 | Extension of Time: Alternative Compliance Schedule for Regulation 1.74- Timing of Acceptance of Trades for Clearing. Barclays Capital Inc. |
10/26/2012 | Request for No-Action Relief for Swap Dealers and Major Swap Participants from Compliance with Certain Internal Business Conduct Requirements Found in Subpart F to Part 23 of the CFTC’s Regulations. Commission Regulations 23.202, 23.203; No-Action 12-29 |
6/01/2012 | No-Action Relief from Provisions of Regulation 1.71. |
10/12/2012 | Time-Limited No-Action Relief: Swaps Only With Certain Persons to be Included in Calculation of Aggregate Gross Notional Amount for Purposes of Swap Dealer De Minimis Exception and Calculation of Whether a Person is a Major Swap Participant. |
10/12/2012 | Time Limited No-action Relief: Foreign Exchange Swaps and Foreign Exchange Forwards Not to be Considered in Calculating Aggregate Gross Notional Amount for Purposes of Swap Dealer De Minimis Exception or in Calculating Substantial Position in Swaps or Substantial Counterparty Exposure for Purposes of the Major Swap Participant Definition. Time-Limited No-action Relief for persons that meet the definitions of Commodity Pool Operators and Commodity Trading Advisors Solely as a Result of their Foreign Exchange Swap and Foreign Exchange Forward Activities. |
10/12/2012 | Time-Limited No-Action Relief: Swaps in Agricultural and Exempt Commodities Not to be Considered in Calculating Aggregate Gross Notional Amount for Purposes of Swap Dealer De Minimis Exception and Calculation of Whether a Person is a Major Swap Participant. |
10/12/2012 | Staff No-Action Relief: Temporary Relief from the De Minimis Threshold for Certain Swaps with Special Entities. |
10/12/2012 | Interpretations and no-action positions related to ECP status. |
10/12/2012 | Time-Limited No-Action Relief: Cleared Swaps in Agricultural and Exempt Commodities and Swaps Exchanged for Futures Not to be Considered in Calculating Aggregate Gross Notional Amount for Purposes of Swap Dealer De Minimis Exception. |
10/12/2012 | Registration Relief for Certain Persons. |
10/11/2012 | Staff No-Action Relief: Preservation of the Regulatory Status Quo with Respect to Certain CEA Provisions That May Apply to FPA Section 201(f) Entities and Other Electric Cooperatives. |
10/11/2012 | Staff No-Action Relief: Preservation of the Regulatory Status Quo with Respect to Certain CEA Provisions That May Apply to RTOs, ISOs, and/or Their Participants. |
10/10/2012 | Division of Clearing and Risk staff issued a no action preserving the regulatory status quo with respect to swaps cleared by a DCO (and related) collateral which expires on the compliance date for Part 22 regulations, November 8, 2012. |
9/26/2012 | The Division of Clearing and Risk granted an extension for compliance with Regulation 1.73(a)(1) for small exchanges and Regulation 1.73(a)(2)(iv)-(v) for automated screening of give-up and bunched orders, until June 1, 2013. 1.73(a)(2)(i), 1.73(a)(2)(iv), 1.73(a)(2)(v); No-Action |
08/14/2012 | Staff No-Action Relief: Temporary Relief for Persons Eligible for the Trade Option Exemption from the Requirements of §§ 32.3(b) and 32.3(c)(1), (3), (4) and (5) of the Commission’s Regulations. |
7/17/2012 | Staff No-Action Relief: Temporary Relief for Non-Clearing Member Swap Dealers from the Requirements of § 20.4 of the Commission’s Regulations Regarding Large Swaps Trader Reporting for Physical Commodities. Part 20: Large Trader Reporting for Physical Commodity Swaps; No-Action |
7/10/2012 | No-Action Relief from Rescission of Regulation 4.13(a)(4) and Amendments to Regulation 4.5. Part 4: Registration and Compliance Obligations for CPOs and CTAs; No-Action |
7/02/2012 | Staff No-Action Relief: Temporary Relief for Clearing Members from the Requirements of Ownership-Level Reporting of § 20.4 of the Commission’s Regulations Regarding Large Swaps Trader Reporting for Physical Commodities. Part 20: Large Trader Reporting for Physical Commodity Swaps; No-Action |