CFTC Staff Letter 14-149: Extension of No-Action Relief for Clearing Corporation of India Ltd.

U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5000
Facsimile: (202) 418-5521 www.cftc.gov
Division of Clearing and
Risk
CFTC Letter No. 14-149
No-Action
December 18, 2014
Division of Clearing and Risk
Mr. R. Sridharan
Managing Director
The Clearing Corporation of India Ltd.
CCIL Bhavan
College Lane, Off. S K Bole Road
Dadar (West)
Mumbai, India
Re: Extension of No-Action Relief with Regard to Section 5b(a) of the Commodity Exchange Act and Commission Regulations Thereunder Dear Mr. Sridharan:
This is in response to your letter dated December 15, 2014 (“Letter”) to the Division of Clearing and Risk (“Division”) of the Commodity Futures Trading Commission (“Commission”). In the Letter, you request that the Division extend the no-action relief granted to Clearing Corporation of India Ltd. (“CCIL”) by letter dated August 18, 2014, from the derivatives clearing organization (“DCO”) registration requirement under Section 5b(a) of the Commodity Exchange Act (“CEA”). Pursuant to the no-action relief, CCIL is permitted to clear Indian Rupee-denominated interest rate swaps (“INR IRS”) and Indian Rupee-denominated forward-rate agreements (“INR FRA”) for the proprietary trades of clearing members that are U.S. persons. The relief is set to expire at the earlier of: (i) December 31, 2014; or (ii) the date on which the Commission either registers CCIL as a DCO under Section 5b(a) of the CEA, or the Commission exempts CCIL from registration pursuant to Section 5b(h) of the CEA. By letter dated November 26, 2014, the Division informed CCIL that it was amenable to extending the no-action relief until December 31, 2015, subject to CCIL notifying the Division, no later than December 15, 2014, that it will file by June 30, 2015: (i) a materially complete Form DCO application for registration as a DCO; or (ii) a petition for an exemption