SIFMA Submits Comments to the CFTC on Requesting Extension of No-Action Relief for CPO Registration (with links to relevant CFTC letters)

SIFMA submitted the attached comments to the CFTC requesting an extension of the time-limited, no-action relief for CPO registration in relation to securitization vehicles granted by CFTC letter 12-45. According to the "SIFMA" letter, a CFTC dialogue with market participants and industry representatives is ongoing. In addition to pending questions raised about the characterization of particular structures, securitization market participants continue to be actively engaged in discussions with the Division of Swap Dealer and Intermediary Oversight regarding the many respects in which the disclosures they mandate, actions they require or information they seek are problematic in the securitization context.

In light of the continuing discussions over these issues, including threshold issues that determine whether registration of a CPO is required at all in respect of certain structures, SIFMA requests in the letter that the Division extend until September 30, 2013.

Click hereto view letter in full (links externally to SIFMA website).See also: CFTC Exclusion from Commodity Pool Regulation for Securitization Vehicles (Letter 12-14) (another important letter dealing with securitization vehicles).See also: CFTC Staff Expands Existing Relief as to Securitizations (with Lofchie Comment) (Letter 12-45).