No-Action Letters

Investment Portals Addressed in SEC Staff Guidance Under JOBS Act; No-Action Letters Also Issued

by Elliott Curzon, Thor Imsdahl, Edward Pittman | Dechert LLP on 5/15/2013

Technology has spawned the formation of new internet-based marketplaces for illiquid and restricted securities. In most instances, these markets are operated by entities registered with the U.S. Securities and Exchange...more

CFTC Staff Issues No-Action Letters

by Kevin M. Foley, Adam J. Spector | Katten Muchin Rosenman LLP on 5/7/2013

Commodity Futures Trading Commission staff recently released two no-action letters providing relief relating to the application of business conduct standards to prime brokers and swap dealers and disclosure of pre-trade...more

Corporate and Financial Weekly Digest - May 3, 2013

by Katten Muchin Rosenman LLP on 5/6/2013

In this issue: - SEC Issues Proposal Regarding Cross-Border Security-Based Swap Activities - CFTC Staff Issues No-Action Letters - Delaware Court Dismisses Securities Fraud Action Against Power Plant...more

SEC's Division of Trading and Markets Grants Relief from Broker-Dealer Registration for Online Platform that Permits Investment in...

by Delcy Sweet | Holland & Knight LLP on 4/17/2013

On March 26, 2013, the SEC's Division of Trading and Markets issued a no-action letter indicating that it would not recommend enforcement action under Section 15(a)(1) of the Exchange Act if a venture capital fund adviser and...more

CFTC Staff Issues No-Action Letters

by Kevin M. Foley, Ross Pazzol, Adam J. Spector | Katten Muchin Rosenman LLP on 4/16/2013

Commodity Futures Trading Commission staff recently released three no-action letters providing relief relating to swap data reporting requirements with respect to trade options, inter-affiliate swaps and real-time reporting...more

Corporate and Financial Weekly Digest - April 12, 2013

by Katten Muchin Rosenman LLP on 4/15/2013

In this issue: - SEC and CFTC Adopt Joint Rules to Help Protect Investors from Identity Theft - CME Block Trade Advisories Clarify Nonpublic Information Restrictions - CFTC Staff Issues No-Action...more

Two Recent SEC No Action Letters Establish Standards for Crowdsourcing Online Platforms Limited to "Accredited Investors" to Avoid...

by Daniel I. DeWolf, Steve Ganis, Jeremy D. Glaser, Melanie Ruthrauff | Mintz Levin - Corporate & Securities on 4/11/2013

In two recent no action letters, the Securities and Exchange Commission (the “SEC”) granted no action relief for two venture capital online funding platforms, the FundersClub, Inc. (“FundersClub”) and AngelList, LLC...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Delays April 10 Compliance Date for Many Swap Data Reporting Requirements"

by Maureen A. Donley, Elizabeth Doyle, Ryan Elsey, Joyce Penn Farnsworth, Ann Hawkins, Theodore M. Kneller, Daniel S. Konar II, Yossi Vebman, Mark D. Young | Skadden, Arps, Slate, Meagher & Flom LLP on 4/11/2013

On April 9, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight, responding to requests from multiple interested parties, issued a no-action letter (the No-Action Letter) extending the April...more

CFTC Staff Issues No-Action Letters

by Blake Brockway, Kevin M. Foley | Katten Muchin Rosenman LLP on 4/10/2013

The Commodity Futures Trading Commission staff recently released a series of letters relating to a variety of regulatory issues, including registration relief for certain entities and recordkeeping requirements for certain...more

CFTC Extends Compliance Dates For End User Swap Reporting

by Nate Endrud | Leonard, Street and Deinard - Dodd-Frank and... on 4/10/2013

The CFTC has issued a no-action letter that effectively extends the dates for swap counterparties who are not swap dealers (SDs) or major swap participants (MSPs) to come into compliance with the agency’s reporting rules...more

"CFTC Issues No-Action Relief From Certain Inter-Affiliate Swap Reporting Requirements"

by Maureen A. Donley, Ryan Elsey, Theodore M. Kneller, Daniel S. Konar II, Mark D. Young | Skadden, Arps, Slate, Meagher & Flom LLP on 4/10/2013

On April 5, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk provided no-action relief (the No-Action Letter) from certain reporting requirements relating...more

SEC No-Action Relief Under the JOBS Act

by Orrick - Structured Finance Group on 4/9/2013

On March 26, the Staff of the Division of Trading and Markets of the SEC provided no-action letter relief from the broker-dealer registration requirements of the Securities Exchange Act of 1934 to FundersClub Inc. and its...more

CFTC No-Action Relief for Commodity Pools

by Orrick - Structured Finance Group on 4/9/2013

On April 2, the CFTC issued a time limited no-action letter that extended the deadline for compliance with reporting for commodity pool operators of securitization vehicles from March 31 until June 30....more

"CFTC No-Action Letter Relieves End-Users of Part 45 Reporting for Trade Options"

by Maureen A. Donley, Erik Elsea, Theodore M. Kneller, Daniel S. Konar II, Mark D. Young | Skadden, Arps, Slate, Meagher & Flom LLP on 4/8/2013

On April 5, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (DMO) provided end-users no-action relief (the No-Action Letter) from certain “trade option” reporting and recordkeeping...more

CFTC No-Action Letter Allows Most End Users To Report All Trade Options On Annual Aggregate Basis

by Nate Endrud | Leonard, Street and Deinard - Dodd-Frank and... on 4/8/2013

The CFTC Division of Market Oversight (DMO) has issued a no-action letter that will allow most swaps end users to report all trade options on an annual aggregate basis. Trade options are commodity options (which include some...more

Corporate and Financial Weekly Digest - April 5, 2013

by Katten Muchin Rosenman LLP on 4/8/2013

In this issue: - SEC Advisory Committee on Small and Emerging Companies Makes Recommendations - SEC Provides Guidance Regarding Social Media and Regulation Fair Disclosure (Regulation FD) - SEC Amends...more

CFTC No-Action Relief for Compliance Reporting

by Orrick - Structured Finance Group on 4/4/2013

On March 28, the CFTC issued a no-action letter providing limited relief, in certain circumstances, from the requirement that chief compliance officers of futures commission merchants prepare and submit an Annual Report....more

CFTC No-Action Relief for Commodity Trader Advisor Registration

by Orrick - Structured Finance Group on 4/4/2013

On March 29, the CFTC issued a no-action letter providing relief, in certain circumstances, from registration as an introducing broker or a commodity trading advisor for certain affiliates of a swap counterparty and certain...more

SEC Staff Provides Additional Rule 14a-8(i)(3) Guidance in No-Action Letter Responses

by Miriam R. Sowinski | Holland & Knight LLP on 4/2/2013

The SEC has elaborated on its Rule 14a-8(i)(3) analysis in its recent responses to registrant request for no-action letters. Shareholder proposals often reference definitions found in NYSE and NASDAQ listing standards...more

CFTC’s No Action Letter Provides Relief From Required Clearing

by Elan Mendel | Shipkevich PLLC on 3/21/2013

The CFTC’s Division of Clearing and Risk issued a no-action letter that provides relief from required clearing for a limited set of “stub swaps.” These are swaps that remain after the partial novation or partial termination...more

Family Office Relief from CPO Registration

by W. Scott McGinness Jr. | Miller & Martin PLLC on 2/26/2013

As noted in an earlier Client bulletin, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued a no-action letter dated November 29, 2012 enabling...more

SEC Issues No-Action Letter on Internet-Based ‘Road Shows’

by Bradley Patterson, Randall Towers | Ballard Spahr LLP on 2/12/2013

The Securities and Exchange Commission has issued a “no-action” letter relating to a provider of electronic-based “road shows.” The SEC stated in the letter, issued on January 29, 2013, that such presentations to retail...more

SEC Extends No-Action Letter Permitting Broker-Dealers to Rely on Certain Investment Advisers to Conduct Customer Identification...

by Janet M. Angstadt, Avi Badash | Katten Muchin Rosenman LLP on 1/22/2013

The Securities and Exchange Commission has extended a no-action letter dated February 12, 2004 (the 2004 Letter) from the Securities Industry Financial Markets Association (SIFMA) that permits broker-dealers, subject to...more

Orrick's Financial Industry Week in Review - January 7, 2013

by Orrick, Herrington & Sutcliffe LLP on 1/14/2013

In This Issue: *Financial Industry Developments - OCC Guidance on Transition Periods under Section 716 of the Dodd-Frank Act - CFTC Reporting of Swap Transactions and Swap Dealer Registration - Department...more

Industry Developments - January 11, 2013

by Orrick - Structured Finance Group on 1/11/2013

From December 14 through December 31, 2012, the CFTC released the following no-action letters: - December 14: Timeline for Swap Dealer Compliance with Large Swap Trader Reporting Rules...more

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Investment Portals Addressed in SEC Staff Guidance Under JOBS Act; No-Action Letters Also Issued

CFTC Staff Issues No-Action Letters

Corporate and Financial Weekly Digest - May 3, 2013

SEC's Division of Trading and Markets Grants Relief from Broker-Dealer Registration for Online Platform that Permits Investment in...

CFTC Staff Issues No-Action Letters

Corporate and Financial Weekly Digest - April 12, 2013

Two Recent SEC No Action Letters Establish Standards for Crowdsourcing Online Platforms Limited to "Accredited Investors" to Avoid...

"CFTC Delays April 10 Compliance Date for Many Swap Data Reporting Requirements"

CFTC Staff Issues No-Action Letters

CFTC Extends Compliance Dates For End User Swap Reporting

"CFTC Issues No-Action Relief From Certain Inter-Affiliate Swap Reporting Requirements"

SEC No-Action Relief Under the JOBS Act

CFTC No-Action Relief for Commodity Pools

"CFTC No-Action Letter Relieves End-Users of Part 45 Reporting for Trade Options"

CFTC No-Action Letter Allows Most End Users To Report All Trade Options On Annual Aggregate Basis

Corporate and Financial Weekly Digest - April 5, 2013

CFTC No-Action Relief for Compliance Reporting

CFTC No-Action Relief for Commodity Trader Advisor Registration

SEC Staff Provides Additional Rule 14a-8(i)(3) Guidance in No-Action Letter Responses

CFTC’s No Action Letter Provides Relief From Required Clearing

Family Office Relief from CPO Registration

SEC Issues No-Action Letter on Internet-Based ‘Road Shows’

SEC Extends No-Action Letter Permitting Broker-Dealers to Rely on Certain Investment Advisers to Conduct Customer Identification...

Orrick's Financial Industry Week in Review - January 7, 2013

Industry Developments - January 11, 2013

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