Commodities Futures Trading Commission No-Action Relief

The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from... more +
The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from fraud, abuse, and systemic risk associated with derivatives subject to the Commodities Exchange Act. In 2010, as a result of the Frank-Dodd Wall Street Reform and Consumer Protection, the Commission’s role was expanded to include drafting rules for regulating the swaps marketplace. less -
News & Analysis as of

CFTC Extends No-Action Relief to Swap Dealers and Major Swap Participants from Compliance with Reporting Obligations

On June 15, CFTC Division of Market Oversight published a letter extending the time-limited relief provided by previously issued no-action letter 14-90, expiring on June 30, 2015, to June 30, 2016. The relief applies to the...more

CFTC Further Extends Valuation Data Reporting Relief for SDs and MSPs

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has further extended no-action relief from the valuation data reporting requirements for cleared swaps under CFTC Regulation 45.4(b)(2)(ii)....more

Financial Services Weekly News Roundup - June 2015 #3

Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more

CFTC Issues Relief From IB and CTA Registration to Foreign Persons Dealing in Swaps for International Financial Institutions

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from introducing broker (IB) and commodity trading advisor (CTA) registration to persons...more

Orrick's Financial Industry Week in Review

SEC Provides Additional Analysis Related to Proposed Pay Ratio Disclosure Rules - On June 4, the Securities and Exchange Commission provided additional analysis related to its proposed rules for pay ratio disclosure. The...more

CFTC Staff Issues No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Persons Located Outside...

On June 4, the Commodity Futures Trading Commission’s (“CFTC”) Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued a No-Action Letter stating that it will not recommend that the CFTC take action for failure to...more

CFTC Issues No-Action Relief to SEFs and DCMs in Connection with Swaps with Operational or Clerical Errors

On April 22, the Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk (Divisions) issued CFTC Letter No. 15-24 to provide no-action relief to enable swap execution facilities...more

CFTC Issues No-Action Relief for SEF Confirmation and Recordkeeping Requirements and Confirmation Data Reporting Requirements

On August 14, 2014, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) granted no-action relief to swap execution facilities (SEFs) from the confirmation and recordkeeping requirements set forth in...more

CFTC Provides Relief in Connection with Erroneous Swap Trades and Swap Trade Confirmations

On April 22, the CFTC issued two no action letters providing relief intended to support the development of swap execution facilities (SEFs) and the trading of swaps on SEFs and designated contract markets (DCMs). The first no...more

CFTC Extends CCO Report Filing Deadline

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued permanent no-action relief from the filing deadline for chief compliance officer (CCO) annual reports....more

CFTC Issues Relief to Swap Dealers Regarding Legacy SPV Swaps

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued no-action relief to swap dealers (SDs) from certain business conduct standards in dealing with...more

CFTC Staff Issues No-Action Relief Regarding CCO Annual Report Timing Requirement

On March 27, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to futures commission merchants, swap dealers and major swap participants from their obligation under...more

CFTC Staff Issues No-Action Relief for Swaps with Legacy SPVs

On March 31, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to provisionally registered swap dealers (SDs) from complying with certain specified regulations when...more

CFTC Issues No-Action Relief for Amended Legacy Swaps between SDs and SPVs

On March 31, 2015, the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the “CFTC”) issued no-action relief regarding compliance with certain of its swap...more

CFTC Issues Advisory on Ownership and Control Reporting

The Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission have issued an advisory on ownership and control reporting (OCR) for futures...more

"CFTC, SEC Issue Guidance on the Applicability of Certain Regulations to Family Offices"

In November and December 2014, the Commodity Futures Trading Commission (the “CFTC”) and Securities and Exchange Commission (“SEC”), respectively, issued guidance regarding the applicability of certain regulations to family...more

Orrick's Financial Industry Week in Review

CFTC Issues No-Action Relief to Certain Introducing Brokers - On January 23, 2015 the CFTC Division of Swap Dealer and Intermediary Oversight issued no-action relief to certain introducing brokers (IBs) with respect to...more

Corporate and Financial Weekly Digest - Volume X, Issue 4

In this issue: - SEC Division of Corporation Finance Issues New C&DI Related to Resales Under Regulation S - SEC Announces Proxy Voting Roundtable - CFTC Staff Issues No-Action Relief From Certain...more

CFTC Issues No-Action Relief to Certain Introducing Brokers

On January 23, 2015 the CFTC Division of Swap Dealer and Intermediary Oversight issued no-action relief to certain introducing brokers (IBs) with respect to net capital and financial reporting requirements under Commission...more

Financial Regulatory Developments Focus - January 2015 #3

In this issue: - US Office of the Comptroller of the Currency Releases Community Reinvestment Act Evaluations - Amendment to Regulation on Supervisory Reporting of Institutions on Asset Encumbrance, Single Data...more

CFTC Staff Extends No-Action Relief to Certain Reporting Counterparties Masking Identifying Information Pursuant to Non-US Law

On January 8, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) granted an extension of previously issued no-action relief for parties required to report identifying...more

CFTC Grants No-Action Relief to Commodity Pool Operators with Respect to Certain Insurance-Linked Securitization Vehicles

Toward the end of 2014, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued two letters affecting insurance-linked securitization vehicles: CFTC...more

Corporate and Financial Weekly Digest - Volume X, Issue 2

In this issue: - New Law Aligns Clearing and Margin Exceptions for Swaps - CFTC Staff Extends No-Action Relief to Certain Reporting Counterparties Masking Identifying Information Pursuant to Non-US Law -...more

CFTC Allows Swap Dealer’s CCO to Report to the Governing Body

On November 25, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter permitting the chief compliance officer (CCO) of a provisionally registered...more

CFTC Staff Issues CCO Annual Report Advisory and Related No-Action Relief

On December 22, 2014, the Division of Swap Dealer and Intermediary Oversight (“DSIO”) of the Commodity Futures Trading Commission (“CFTC”) issued an Advisory providing guidance regarding the contents of chief compliance...more

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