CFTC Staff Letter 00-41: Extension of No-Action Relief for FTSE Euro Symbol Stars Index

00-41
CFTC Letter No. 00-41
March 14, 2000
Exemption
Division of Trading & Markets
VIA FACSIMILE and U.S. MAIL
N. P. Weinrub
Director, Market Secretariat
The London International Financial
Futures and Options Exchange
Cannon Bridge House
1 Cousin Lane
London EC4R 3XX
Re: Sections 5 and 5a - LIFFE Administration and Management; Second Request for Supplemental No-Action Relief From Contract Market Designation Requirement Dear Mr. Weinrub:
This is in response to your letter dated February 16, 2000 to the Division of Trading and Markets ("Division") of the Commodity Futures Trading Commission ("Commission''), as supplemented by telephone conversations with Division staff. By this correspondence, you request, on behalf of LIFFE Administration and Management ("LIFFE") and its members,1 that the Division extend the no-action relief granted to LIFFE by its letter dated July 23, 1999 ("July 23 Letter")2 to the FTSE International euro symbol Stars Index ("FTSE euro symbol Stars Index") futures contract. In its July 23 Letter, the Division granted LIFFE no-action relief to permit it to make its electronic trading and order matching system, known as "LIFFE CONNECTTM," available to LIFFE's members in the United States without obtaining contract market designation pursuant to Sections 5 and 5a of the Commodity Exchange Act.3 Specifically, the Division agreed not to recommend that the Commission institute enforcement action against LIFFE or its members if: (i) LIFFE members trade for their proprietary accounts through LIFFE CONNECTTM in the United States; (ii) LIFFE members who are registered with the Commission as futures commission merchants ("FCMs") or who are exempt from registration pursuant to Rule 30.10 ("Rule 30.10 Firms") submit orders from United States customers for transmission to LIFFE CONNECTTM; and/or (iii) LIFFE members who are registered with the file:///S|/Website%20Management/LegacyDataCopyasof2010-04-21/tm/letters/00letters/tm00-41.htm (1 of 4) [5/6/2010 6:20:16 PM]