CFTC Grants Relief from Commodity Pool Operator Registration for Insurance-Linked Securities Issued by SPVs

23 December 2014
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Key takeaways

  • The Division of Swap Dealer and Intermediary Oversight of the CFTC issued a no-action letter granting relief from commodity pool operator registration for entities engaging in insurance-linked securities transactions, subject to certain conditions. The relief was granted in response to a letter from the Securities Industry and Financial Markets Association.
  • The relief allows operators of entities engaging in such transactions not to register as a commodity pool operator if they satisfy the conditions of the de minimis exemption in CFTC regulation 4.13(a)(3) and certain other conditions set forth in the no-action letter.