CFTC No-Action Relief for Family Offices

The CFTC issued the attached no-action letter regarding family offices, stating that the Division of Swap Dealer and Intermediary Oversight will not recommend that the CFTC take action against the operators of family offices for failure to register as CPOs under the Commodity Exchange Act and CFTC rules thereunder, subject to certain conditions described in the letter. The most important conditions are that (i) the CPO must be acting with regard to a "family office" as defined inAdvisers Act Rule 202(a)(11)(G)-1 and (ii) a notice claiming the exemption must be submitted to the CFTC with certain specified information. Cross-Reference(s): CFTC Rules Part 3("Registration") and 4 ("CPOs and CTAs").

See: CFTC Letter 12-37: Parts 3 and 4; No-Action