• CFTC Staff Issues No-Action Letter Concerning Relief from Rescission of CFTC Rule 4.13(a)(4) and Amendments to Rule 4.5
  • July 27, 2012 | Authors: William J. Breslin; Robert M. McLaughlin; David S. Mitchell; Fern B. Simmons
  • Law Firms: Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office ; Fried, Frank, Harris, Shriver & Jacobson LLP - New York Office ; Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office
  • On July 13, 2012, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (the “CFTC”) issued a no-action letter responding to a request for no-action relief submitted by the Managed Funds Association, the Investment Adviser Association, the Alternative Investment Management Association, Ltd., and the Investment Company Institute for additional time to comply with (i) the inclusion of swaps in the de minimis threshold calculation under CFTC Rule 4.13(a)(3) (and Rule 4.5 for registered investment companies) and (ii) the rescission of CFTC Rule 4.13(a)(4) (and the amendments to Rule 4.5 with respect to registered investment companies).