Further Exclusions From Commodity Pool Regulation for Certain Securitization Vehicles; No-Action Relief for Certain Securitization Vehicles Formed Prior to October 12, 2012
Issues Covered in the No-Action Letter
On December 7, 2012, the US Commodity Futures Trading Commission's ("CFTC") Division of Swap Dealer and Intermediary Oversight (the "Division") issued a no-action letter, number 12-45 (the "12-45 No-Action Letter"), providing (1) further interpretations regarding when exclusions from commodity pool regulation is appropriate, (2) no-action relief for operators of certain securitization vehicles formed prior to October 12, 2012, from failure to register as a CPO and (3) temporary no-action relief for certain securitization vehicles that may not otherwise rely on the no-action relief granted by the 12-14 No-Action Letter or the 12-45 No-Action Letter from failure to register as a CPO until March 31, 2013.
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