CFTC No-Action Relief for SGX-DT Mini Nikkei 225 Futures Contract Offer and Sale in the U.S.

U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5120
Facsimile: (202) 418-5524
Office of General Counsel

CFTC Letter No. 09-48
No-Action
December 23, 2009
Office of General Counsel
Ms. Janice Kan
Vice President
Head, Product Development
Development Group
Singapore Exchange, Ltd.
2 Shenton Way, #19-00, SGX Centre 1
Singapore 068804
Re: Singapore Exchange Derivatives Trading Limited’s Request for No-Action Relief in Connection with the Offer and Sale in the United States of its Mini Futures Contract Based on the Nikkei 225 Stock Index Dear Ms. Kan:
This is in response to your letter dated June 3, 2008, requesting on behalf of the Singapore Exchange Derivatives Trading Limited (“SGX-DT”), that the Office of General Counsel (“Office”) of the Commodity Futures Trading Commission (“Commission” or "CFTC") issue a no-action letter concerning the offer and sale in the United States (“U.S.”) of SGX-DT’s mini futures contract based on the Nikkei 225 Stock Index (“Nikkei 225” or “Index”). The Nikkei 225 is a broad-based, price-weighted composite security index (the unit is yen) made up of highly capitalized and actively traded stocks currently listed in the first section of the Tokyo Stock Exchange. As a widely recognized index of stock market activity in Japan, the Nikkei 225 is similar to the Dow Jones Industrial Average in the U.S.