CFTC Issues CPO Registration Relief to Issuers of Certain Insurance-Linked Securities (CFTC Letter 14-152)

The CFTC Division of Swap Dealer and Intermediary Oversight issued a letter providing no-action relief to entities operating issuers of insurance-linked securities ("ILS Issuer") subject to specific conditions.

The operator of an ILS Issuer that meets the conditions outlined in the letter may claim an exemption from CPO registration consistent with CFTC Rule 4.13(a)(3) ("Exemption From Registration as a Commodity Pool Operator"), with respect to the issuance of insurance-linked securities. In addition to meeting the operational and substantive conditions of relief, an operator of an ILS Issuer must file a notice of exemption with the NFA to claim the relief.

See: CFTC Letter 14-152; CFTC Press Release.