On December 23, CFTC provided guidance regarding requirements imposed on commodity trading advisors (CTAs) resulting from Dodd-Frank on the potential new advisory obligations of CTAs. Release.
commodity trading advisors
CFTC No-Action Letters
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
- December 14: Annual Reports of Chief Compliance Officers for Swap Dealers
- December 17: Reporting of Unique Swap Identifier by Prime Brokers
- December 17: Compliance with Reporting Obligations by Swap Dealers and Major Swap Participants
- December 18: Japan Securities Clearing Corporation and its Clearing Participants
- December 18: Treatment of Swap Transactions on Natural Gas Exchange for Calculations under the Swap Dealer Definition
- December 18: Obligation of Swap Dealers and Major Swap Participants to provide Pre-Trade Mid-Market Mark for certain Credit Default Swaps and Interest Rate Swaps
- December 19: Reporting Provisions for Swap Dealers and Major Swap Participants for CDS Clearing-Relating Swaps
- December 19: Treatment of Swap Transactions by persons engaging in Floor Trader Activities for purposes of Swap Dealer Definition Calculations
- December 21: Treatment of Swap Transactions arising from Multilateral Portfolio Compression Exercises for purposes of Swap Dealer Definition Calculations
- December 21: Legal Entity Identifiers and Certain Identifying Information
- December 21: Singapore Exchange Derivatives Clearing Limited and its Clearing Members
- December 21: Compo Equity Total Return Swaps
- December 21: Reporting of Certain Non-Reporting Counterparty Information
- December 21: Swap Data Reporting Relief for Swap Dealers
- December 21: Registration Relief for Operators in Investment Pools that invest in Legacy Securitization Vehicles
- December 21: Registration Relief for Certain Commodity Pool Operators, Commodity Trading Advisors or any Principal or Associated Person required to register
- December 21: Registration Relief for Certain Associated Persons required to register as a commission merchant
- December 31: Registration Relief for Certain Introducing Brokers and Commodity Trading Advisors Involved in Swaps Activities
- December 31: Relief for Certain U.S. Banks Wholly Owned by non-U.S. Swap Dealers for purposes of Swap Dealer Definition Calculations
CFTC Swap No-Action Relief for Registration and Compliance
On July 13, the CFTC announced time-limited no-action relief for commodity pool operators (CPOs) and commodity trading advisors (CTAs) who have been exempt or excluded from registration but, because of recent amendments to Commission Regulations 4.13 and 4.5, now need to register and satisfy compliance obligations. Under the relief, the CFTC will not take will not take enforcement actions against CPOs or CTAs for failure to register until December 31, subject to satisfaction of requirements including filing of a notice. CFTC Release.