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CFTC Registration Relief for Foreign CPOs and CTAs: Correct Result, Incorrect Reasoning?
22 February 2016
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The CFTC recently issued a no-action letter to provide CPOs, CTAs and IBs located outside of the United States acting for non-US clients with relief from registration requirements even if they trade uncleared swaps.
The CFTC should amend the rules to provide further guidance on registration exemptions for such non-US intermediaries and expand their permitted activities.
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