RegAlert2012-11-29 | CFTC Staff Letter 12-33Added · Updated
CFTC Staff Letter 12-33: No-Action Relief from Regulation 23.451 for Governmental Plans and Look-Back Clarification
The Division of Swap Dealer and Intermediary Oversight will not recommend enforcement against swap dealers and their covered associates for failing to comply with Regulation 23.451’s prohibition on political contributions regarding governmental plans defined in Section 3 of ERISA, provided those plans are not otherwise covered by SEC or MSRB rules. The Division clarifies that the two-year look-back period for prohibited contributions does not include any time preceding the date an entity is required to register as a swap dealer.
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U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5977
Facsimile: (202) 418-5407 gbarnett@cftc.gov
Division of Swap Dealer and
Intermediary Oversight
Gary Barnett
Director
CFTC Letter No. 12-33 Amended
No-Action
November 29, 2012
Division of Swap Dealer and Intermediary Oversight Re: Requests for No-Action Relief from Commission Regulation 23.451 in Connection with Dealings with Certain Governmental Plans and for Clarification Concerning the “Look-Back” Provision of Commission Regulation 23.451 Ladies and Gentlemen:
This letter responds to submissions addressed to the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“Commission”) requesting no-action relief from Commission Regulation (“Regulation”)
23.451 1
in connection with swap dealers’ (“SDs”) and their covered associates’ dealings with certain “governmental plans” as defined in the Employee Retirement Income Security Act of 1974 (“ERISA”). Additionally, this letter addresses questions raised about the application of the “look-back” provision in Regulation 23.451.
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Source: Commodity Futures Trading Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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CFTC published 6 documents in the last 30 days. We email you each new one the day it's published.