On October 12, the CFTC released a number of no-action letters and interpretive guidance addressing:
- Swap calculation by certain foreign entities for purposes of the swap dealer and major swap participant definitions. CFTC Release. CFTC Letter No.12-22.
- Temporary relief for foreign exchange swaps and foreign exchange forwards in the major swap participant and swap dealer calculations and a related temporary registration exemption for CPO and CTA registration. CFTC Release. CFTC Letter No.12-21.
- Treatment of agricultural and exempt commodities for swap dealer and major swap participant calculations. CFTC Release. CFTC Letter No.12-20.
- The scope of the bona fide hedging exemption from the trading thresholds as applied to registered investment companies. CFTC Release. CFTC Letter No.12-19.
- The de minimis threshold for swaps with utility special entities. CFTC Release. CFTC Letter No.12-18.
- Interpretation of the eligible contract participant requirements. CFTC Release. CFTC Letter No.12-17.
- Temporary relief from registration for swap intermediaries. CFTC Release. CFTC Letter No.12-15.