CFTC Provides Limited No-Action Time-Relief for Operators of Certain Funds of Funds

The CFTC issued the attached time-limited no-action relief to the operators of funds of funds, stating that the Division of Swap Dealer and Intermediary Oversight (DSIO) will not recommend that the CFTC take action against the CPO of a fund of funds for failure to register as such until the later of June 30, 2013, or six months after the effective date (or compliance date, if later) of any revised guidance that DSIO issues on the application of the de minimis thresholds to funds of funds. This relief applies within the context of CFTC Rules 4.5 and 4.13(a)(3), provided that the CPO files a claim for no-action relief and that claim meets certain criteria specified in the letter.

See: CFTC Letter 12-38: Parts 3 and 4; No-Action