18-12 ; Commission Regulation 150.4(a) and 150.4(b)(1); Interpretative The staff letter confirms that, for purposes of applying the position limits set forth in CFTC Regulation 150.2, when an institutional investor qualifies for the Regulation 150.4(b)(1) exemption from position aggregation with respect to their investment in a fund, the institutional investor is not required to look through its investment in a fund to aggregate commodity interest positions of an underlying portfolio company in which the institutional investor may hold a 10 percent or greater indirect interest (via its investment in the fund).
18-11 ; CFTC Regulations 4.22(d) and 4.27(c); Other Written Communications Rescission of CFTC Staff Letter No. 16-47
18-10 ; CFTC Regulation 4.7(b)(3); Exemption Previous annual report exemptive relief granted to a CPO extended to an additional subsidiary pool; condition in previous exemptive relief with respect to an existing subsidiary pool removed based on changed circumstances.
18-09 ; Commission Regulations 4.7 and 4.22;; Exemption Exemptive relief from the provisions of Commission Regulations 4.7 and 4.22 to prepare an onshore feeder fund’s financial statements in accordance with U.S. GAAP
18-07 ; Regulations 4.12(a), 4.7(b)(3), and 140.93;; Exemption DSIO denied a CPO’s request for exemptive relief from the audited annual report requirement for its pools because Division staff concluded that avoiding the audit could be disadvantageous for participants.
18-06 ; Commission Regulation 4.7(b)(2);; Exemption Exemption
Exemptive relief from the requirement in Commission regulation 4.7(b)(2) to distribute quarterly account statements to participants within 30 days after the end of each quarter, instead providing information within 45 days after the end of each month.
18-08 ; CEA Section 4m(1), Regulations 4.5 and 4.6;; No-Action The Division of Swap Dealer and Intermediary Oversight provided no-action relief from CPO and CTA registration to the trustee of a pension plan group trust comprised solely of pension plans that are “not construed to be pools” under Regulation 4.5(a)(4)(i)-(iii).
18-04 ; CEA Section 5b(a) and the Commission regulations thereunder; No-Action No-Action
Extension of time-limited no-action relief for Shanghai Clearing House with regard to Section 5b(a) of the Commodity Exchange Act and Commission Regulations thereunder.
18-05 ; Commission Regulation 4.7(b)(2); Exemption Exemptive relief from the requirement in Commission regulation 4.7(b)(2) to distribute quarterly account statements to participants within 30 days after the end of each quarter. Instead, the operator will provide the information required to be contained in a quarterly account statement on a monthly basis, and within 45 days after the end of each month.
18-03 ; Sections 45.3, 45.4, 45.5, and Appendix 1 of Part 45; No-Action No-Action
Extension of no-action relief originally granted by DMO on December 19, 2016 to counterparties clearing swaps through derivatives clearing organizations acting under exemptive or no-action relief from certain reporting obligations for cleared swaps under Part 45 of the Commission's regulations.