CFTC Staff Letter 07-07: No-Action Relief for SGX-DT U.S. Dollar Nikkei 225 Futures

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

CFTC letter No. 07-07
May 24, 2007
No-Action
Office of General Counsel
Ms. Adeline Ee
Vice President
Members & Institutions Business, Markets Group Singapore Exchange, Ltd.
2 Shenton Way, #19-00, SGX Centre 1
Singapore 068804
Re: Request for No-action Relief to Offer and Sell in the United States Singapore Exchange Derivatives Trading Limited’s U.S. Dollar Denominated Nikkei 225 Index Futures Contract Dear Ms. Ee:
This is in response to your letter dated December 20, 2006, requesting on behalf of Singapore Exchange Derivatives Trading Limited (“SGX-DT”) that the Office of General Counsel (“Office”) of the U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) issue a no-action letter concerning the offer and sale in the United States (“U.S.”) of SGX-DT’s U.S. dollar denominated futures contract based on the Nikkei 225 Index (“Nikkei 225” or “Index”). We understand that on November 24, 2006, SGX-DT added to its current suite of Nikkei contracts a cash settled U.S. dollar denominated version of the Nikkei 225 futures contract. The U.S. dollar denominated version is targeted at investors who prefer a U.S. dollar exposure to the Japanese market. A similar U.S. dollar denominated futures contract is listed and traded on the Chicago Mercantile Exchange (“CME”). SGX-DT intends to make its U.S. dollar denominated contract available on the Mutual Offset Facility with the CME. In 1986, this Office issued no-action relief to permit the offer and sale in the U.S. of SGX-DT’s Japanese yen denominated futures contract based on the Nikkei 225.1 The terms and conditions of the U.S. dollar denominated version that is the subject of this request are substantially identical to the Japanese yen denominated version that received no-action relief, except that the subject contract is denominated in U.S. dollars. Specifically, the contract 1 See CFTC Staff Letter No. 86-6, [1986-1987 Transfer Binder] Comm. Fut. L. Rep. (CCH) ¶ 23,395 (Dec. 5, 1986).