In a no-action letter aimed at swap dealers, the Commodity Futures Trading Commission (“CFTC”) Market Participants Division, Division of Clearing and Risk, Division of Data, and Division of Market Oversight offered Brexit-related no-action for some transaction level...
Broader guidance for our market emerged in the Division of Clearing and Risk’s letter 21-08 about the CFTC’s regulation 39.13(g)(8)(ii). Referring back to its own interpretive letter 12-08, the Division of Clearing and Risk pointed out that the CFTC had adopted many...
The CFTC’s Market Participants Division next issued an exemption via letter 21-07, permitting an introducing broker not to file a required CFTC form for 2020. Staff reasoned that because the broker in question had registered as an introducing broker with 21 days...
In no-action letter 21-06, the Market Participants Division of the Commodity Futures Trading Commission (“CFTC”) agreed that a company with a primary business of biopharmaceutical royalty returns needn’t register as a commodity pool operator when hedging its debt with...
In determination letter 21-03, Market Participants Division staff approved a swap dealer capital model proposal from the National Futures Association (“NFA”). And the Market Participants Division joined the Division of Market Oversight to release two no-action letters...
