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Swap Dealers No-Action Letters Commodity Pool Operator

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Staff Issues Long-Awaited CPO Delegation Relief"

On May 12, 2014, the Division of Swap Dealer and Intermediary Oversight (Division) of the Commodity Futures Trading Commission (CFTC) released its long-awaited commodity pool operator (CPO) delegation no-action letter...more

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Letters

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

Orrick - Finance 20/20

CFTC No-Action Relief for Mortgage REIT Operators from Commodity Pool Operator Registration

Orrick - Finance 20/20 on

On December 7, the CFTC issued a no-action letter to mortgage real estate investment trusts which provides that the Division of Swap Dealer and Intermediary Oversight will not recommend that the CFTC take enforcement action...more

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