# CFTC Letter No. 08-05: Eurex Deutschlands Request for No-Action Relief in Connection with the Offer and Sale in the United States of its Futures Contract Based on the RDXxt USD-RDX Extended Index

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/CFTC_L08_05

## Section

- **Citation:** CFTC Letter No. 08-05
- **Heading:** Eurex Deutschlands Request for No-Action Relief in Connection with the Offer and Sale in the United States of its Futures Contract Based on the RDXxt USD-RDX Extended Index
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** CFTC Staff Letters (2008-present) / Eurex Deutschlands Request for No-Action Relief in Connection with the Offer and Sale in the United States of its Futures Contract Based on the RDXxt USD-RDX Extended Index.

## Text

Summary: Eurex Deutschlands Request for No-Action Relief in Connection with the Offer and Sale in the United States of its Futures Contract Based on the RDXxt USD-RDX Extended Index.

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. 08-05
March 6, 2008
No-Action
Office of General Counsel

Paul M. Architzel, Esq.
Alston & Bird LLP
950 F Street, N.W.
The Atlantic Building
Washington, DC 20004

Re:
Eurex Deutschland’s Request for No-Action Relief in Connection with the

Offer and Sale in the United States of its Futures Contract Based on the

RDXxt USD-RDX Extended Index

Dear Mr. Architzel:

This letter is in response to letters, attachments, facsimiles and electronic mail dated from
April 10, 2007 to November 16, 2007, requesting on behalf of Eurex Deutschland (“Eurex”) 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 Eurex’s futures contract based on the RDXxt USD-RDX Extended Index
(“RDXxt” or “Index”).

We understand the facts to be as follows. Eurex is a futures and options exchange
located in Frankfurt, Germany and operated by Eurex Frankfurt AG.1 Eurex is regulated by and
subject to active market surveillance by German regulatory agencies, including the Exchange
Supervisory Authority in the State of Hesse, where Eurex is located, and by the German Federal
Financial Supervisory Agency (Bundesanstalt für Finanzdienstleistungsaufsicht) (the “BaFin”)
s and options exchange
located in Frankfurt, Germany and operated by Eurex Frankfurt AG.1 Eurex is regulated by and
subject to active market surveillance by German regulatory agencies, including the Exchange
Supervisory Authority in the State of Hesse, where Eurex is located, and by the German Federal
Financial Supervisory Agency (Bundesanstalt für Finanzdienstleistungsaufsicht) (the “BaFin”).
Pursuant to the German Securities Trading Act, the BaFin has responsibility for the supervision
of German securities and derivatives trading and has the authority to cooperate with competent
authorities of other countries in connection with the supervision of securities and derivatives

1 This Office previously has granted no-action relief to Eurex in connection with the offer and
sale in the U.S. of a number of Eurex’s futures contracts based on non-narrow-based security
indices, most recently see CFTC Staff Letter No. 08-03 (Feb. 6, 2008).

markets and trading activity thereon, including by sharing non-public market surveillance
information.2

The RDXxt is a broad-based, modified market capitalization weighted security index
composed of at least 15 of the most highly capitalized and actively traded American Depositary
Receipts/Global Depositary Receipts3 on Russian blue chip companies traded on the London
Stock Exchange’s (“LSE’s”) International Order Book (“IOB”).4 The Index is calculated by
Wiener Börse AG (“WBAG”), Austria, which operates and manages Wiener Börse (the Vienna
Stock Exchange), a securities and general commodity exchange authorized by the Austrian
Ministries of Finance and Economic Affairs under the Austrian Stock Exchange Act. WBAG
employs a selection committee to determine Index composition.5

2 See letter from Paul M. Architzel, Alston & Bird LLP to Elizabeth L. Ritter, Deputy General
Counsel, CFTC, dated April 10, 2007, at 7
and general commodity exchange authorized by the Austrian
Ministries of Finance and Economic Affairs under the Austrian Stock Exchange Act. WBAG
employs a selection committee to determine Index composition.5

2 See letter from Paul M. Architzel, Alston & Bird LLP to Elizabeth L. Ritter, Deputy General
Counsel, CFTC, dated April 10, 2007, at 7.

3 An American Depositary Receipt (“ADR”) is used to trade the stock of a foreign company in
the U.S. Each ADR is issued by a U.S. depositary bank and represents one or more shares of a
foreign stock or a fraction thereof. If investors own an ADR they have the right to obtain the
foreign stock it represents. The price of an ADR is often close to the price of the foreign stock in
its home market, adjusted for the ratio of ADRs to foreign company shares. According to the
LSE, ADRs listed in London are fungible and compatible with U.S.-listed ADRs, and U.S.
investors may trade them. A Global Depositary Receipt (“GDR”) is a bank certificate issued in
more than one country for shares in a foreign company. The shares are held by a foreign branch
of an international bank. The shares trade as domestic shares, but are offered for sale globally
through the various bank branches. Id. at 1-2 n.1.

4 The IOB is a facility of the LSE for the trading of developing market depositary receipts. It is a
public order limit order book. IOB trades may be matched electronically. These trades are
known as “Automatic” trades. Off-order book trades may also be negotiated directly between
members (usually over the telephone) and reported by the members. Only Automatic trades are
used in calculating the RDXxt. Id. at 4, 7 and n.6.

5 The selection committee is composed of a chairperson and representatives of WBAG, members
of Wiener Börse, financial institutions that issue financial products based on the Index, academic
consultants and local market experts
d directly between
members (usually over the telephone) and reported by the members. Only Automatic trades are
used in calculating the RDXxt. Id. at 4, 7 and n.6.

5 The selection committee is composed of a chairperson and representatives of WBAG, members
of Wiener Börse, financial institutions that issue financial products based on the Index, academic
consultants and local market experts. The selection committee is required to act objectively, for
the benefit of investors and investor protection. Selection of underlying securities for inclusion
in the Index by the selection committee is not automatic, but is guided by selection rules adopted
and published by WBAG. The most important selection criteria are market capitalization and
liquidity; additional criteria include price availability of the depositary receipt, sector
representativeness, market interest and exchange listing. The selection committee meets
quarterly to review and adjust the weighting factors and meets semi-annually in March and
September to make changes to index composition. On an as needed basis, the selection
committee may adjust the Index periodically and for unusual events, such as stock-splits,
mergers, spinoffs, de-listings and bankruptcies, but the Index is not adjusted for dividend
payments. All resolutions of the committee are made publicly available immediately after a
decision has been made. Rule 7.2.2 of the Wiener Börse, as recently amended, requires that

2
eded basis, the selection
committee may adjust the Index periodically and for unusual events, such as stock-splits,
mergers, spinoffs, de-listings and bankruptcies, but the Index is not adjusted for dividend
payments. All resolutions of the committee are made publicly available immediately after a
decision has been made. Rule 7.2.2 of the Wiener Börse, as recently amended, requires that

2

The weighting of each of the underlying depositary receipts within the RDXxt is
determined by its weighted market capitalization, which is calculated by multiplying the number
of shares outstanding by the current price of the depositary receipts on the LSE and the relevant
conversion factor for depositary receipts, multiplied by the weighting factors. The number of
shares outstanding used in this weighting is the number of shares declared deliverable on the
Russian Trading System (“RTS”), the Moscow Interbank Currency Exchange (“MICEX”), or
any other reliable source. The conversion factor for depositary receipts is defined as the
conversion ratio of depositary receipts divided by the underlying shares of common stock. The
weighting factors include a “free float,” which is determined by WBAG based on information
from the market on which a stock is listed to reduce the influence that a stock with a high
capitalization but a relatively small free float may have on the Index, and a representation factor,
which ensures that no constituent security will exceed 10% of the weighting of the Index.6

As of February 19, 2008, the RDXxt included 17 depositary receipts and had a total
adjusted market capitalization of approximately U.S.$ 135.5 billion.7 The largest single
component security by weight represented approximately 11.62%, and the five most heavily-
weighted component securities represented 47.15%, of the RDXxt
constituent security will exceed 10% of the weighting of the Index.6

As of February 19, 2008, the RDXxt included 17 depositary receipts and had a total
adjusted market capitalization of approximately U.S.$ 135.5 billion.7 The largest single
component security by weight represented approximately 11.62%, and the five most heavily-
weighted component securities represented 47.15%, of the RDXxt. The securities comprising
the lowest 25% by weight of the RDXxt had a six-month aggregate dollar value of average daily
trading volume of approximately U.S.$ 67.6 million for the six-month period ending February
2007.8 The RDXxt is calculated in real time in both euros and U.S. dollars and disseminated by
electronic means through major data vendors, by daily e-mail service and on WBAG’s website at
www.wienerborse.at or www.indices.cc.9

Eurex’s futures contract is based on the U.S. dollar calculated version of the RDXxt and
provides for cash settlement. Prices for Eurex’s contract are quoted in Index points, with each
Index point equal to U.S.$ 25 per contract. The minimum price movement is one-half of one
Index point, representing a value of U.S.$ 12.50. Eurex lists for trading the three nearest months
of the March quarterly cycle (March, June, September and December). The last trading day of
the contract is the third Friday of the relevant expiration month (or, if such day is not a trading

"[a]ll members of the RDXxt Committee must preserve the confidentiality of all matters
discussed before they are disseminated to the public, act in good faith and with a view to the
interest of investors and investor protection." Trading in Eurex’s RDXxt futures contract by
members of the committee is considered to be trading in material, non-public information, which
is prohibited by Article 48b of the Austrian Exchange Act. See letter from Mr
e confidentiality of all matters
discussed before they are disseminated to the public, act in good faith and with a view to the
interest of investors and investor protection." Trading in Eurex’s RDXxt futures contract by
members of the committee is considered to be trading in material, non-public information, which
is prohibited by Article 48b of the Austrian Exchange Act. See letter from Mr. Architzel to Ms.
Ritter, dated April 10, 2007 at 5-6 and electronic mail from Mr. Architzel to Julian E. Hammar,
Assistant General Counsel, CFTC, dated September 10, 2007.

6 See letter from Mr. Architzel to Ms. Ritter, dated April 10, 2007, at 5-6 and Appendix A.

7 Market capitalization and weighting data were obtained from Weiner Börse’s website.

8 See letter from Mr. Architzel to Ms. Ritter, dated April 10, 2007, at Appendix D.

9 Id. at 7.

3

day, the trading day immediately preceding such Friday). Cash settlement occurs on the first
trading day after the last trading day of the contract. The final cash settlement price is the
closing level of the RDXxt on the last trading day based on closing prices at 5:00 p.m. CET at
the LSE’s IOB.10

The Commodity Exchange Act (“CEA”),11 as amended by the Commodity Futures
Modernization Act of 2000 (“CFMA”),12 provides that the offer or sale in the U.S. of futures
contracts based on a group or index of securities (including those contracts traded on or subject
to the rules of a foreign board of trade) is subject to the Commission's exclusive jurisdiction,13
with the exception of security futures products,14 over which the Commission shares jurisdiction
with the Securities and Exchange Commission (“SEC”).15 Thus, the Commission’s jurisdiction
remains exclusive with regard to futures contracts on a group or index of securities that is broad-
based pursuant to CEA Section 1a(25).16

CEA Section 2(a)(1)(C)(iv) generally prohibits any person from offering or selling a
futures contract based on a security index in the U.S., except as permitted un
ith the Securities and Exchange Commission (“SEC”).15 Thus, the Commission’s jurisdiction
remains exclusive with regard to futures contracts on a group or index of securities that is broad-
based pursuant to CEA Section 1a(25).16

CEA Section 2(a)(1)(C)(iv) generally prohibits any person from offering or selling a
futures contract based on a security index in the U.S., except as permitted under CEA Section
2(a)(1)(C)(ii) or CEA Section 2(a)(1)(D).17 By its terms, CEA Section 2(a)(1)(C)(iv) applies to
futures contracts on security indices traded on both domestic and foreign boards of trade. CEA
Section 2(a)(1)(C)(ii) sets forth three criteria to govern the trading of futures contracts on a group
or index of securities on designated contract markets and registered derivatives transaction
execution facilities (“DTEFs”):

(1)
the contract must provide for cash settlement;

(2)
the contract must not be readily susceptible to manipulation nor to being

used to manipulate any underlying security; and

10 Id. at 9 and Appendix C.
11 7 U.S.C. § 1 et seq.

12 Appendix E of Pub. L. No. 106-554, 114 Stat. 2763 (2000).

13 See CEA Section 2(a)(1)(C)(ii).

14 Security futures products are defined as a security future or any put, call, straddle, option, or
privilege on any security future. See CEA Section 1a(32). A security future is defined as a
contract of sale for future delivery of a single security or of a narrow-based security index,
including any interest therein or based on the value thereof, with certain exceptions. See CEA
Section 1a(31).

15 See CEA Section 2(a)(1)(D).

16 See CEA Section 2(a)(1)(C)(ii).

17 CEA Section 2(a)(1)(D) governs the offer and sale of security futures products.

4
ty future is defined as a
contract of sale for future delivery of a single security or of a narrow-based security index,
including any interest therein or based on the value thereof, with certain exceptions. See CEA
Section 1a(31).

15 See CEA Section 2(a)(1)(D).

16 See CEA Section 2(a)(1)(C)(ii).

17 CEA Section 2(a)(1)(D) governs the offer and sale of security futures products.

4

(3)
the group or index of securities must not constitute a narrow-based

security index.18

While Section 2(a)(1)(C)(ii) provides that no designated contract market or DTEF may
trade a security index futures contract unless it meets the three criteria noted above, it does not
explicitly address the standards to be applied to a foreign security index futures contract traded
on a foreign board of trade. This Office has applied those same three criteria in evaluating
requests by foreign boards of trade to allow the offer and sale within the U.S. of their foreign
security index futures contracts when those foreign boards of trade do not seek designation as a
contract market or registration as a DTEF to trade those products.19

Accordingly, Commission staff has examined the RDXxt, and Eurex’s futures contract
based thereon, to determine whether the Index and the futures contract meet the requirements
enumerated in CEA Section 2(a)(1)(C)(ii). Based on the information noted herein and as set
forth in the letters, attachments, facsimiles and electronic mail noted above, we have determined
that the RDXxt, and Eurex’s futures contract based thereon, conform to these requirements.20

18 The first two criteria under CEA Section 2(a)(1)(C)(ii) were unchanged by the CFMA. With
regard to the third criterion, an index is a “narrow-based security index” under both the CEA and
the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C
that the RDXxt, and Eurex’s futures contract based thereon, conform to these requirements.20

18 The first two criteria under CEA Section 2(a)(1)(C)(ii) were unchanged by the CFMA. With
regard to the third criterion, an index is a “narrow-based security index” under both the CEA and
the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. § 78a et seq., if it has any one
of the following four characteristics: (1) it has nine or fewer component securities; (2) any one
of its component securities comprises more than 30% of its weighting; (3) the five highest
weighted component securities in the aggregate comprise more than 60% of the index’s
weighting; or (4) the lowest weighted component securities comprising, in the aggregate, 25% of
the index’s weighting, have an aggregate dollar value of average daily trading volume of less
than $50 million (or in the case of an index with 15 or more component securities, $30 million).
See CEA Section 1a(25)(A)(i)-(iv); Exchange Act Section 3(a)(55)(B)(i)-(iv). Thus, an index
that does not have any of these elements is not a narrow-based security index for purposes of
CEA Section 2(a)(1)(C)(ii). See also CEA Section 1a(25)(B); Exchange Act Section
3(a)(55)(C).

19 With regard to the third criterion, the CFTC and SEC jointly promulgated Rule 41.13 under
the CEA and Rule 3a55-3 under the Exchange Act, governing security index futures contracts
traded on foreign boards of trade. These rules provide that “[w]hen a contract of sale for future
delivery on a security index is traded on or subject to the rules of a foreign board of trade, such
index shall not be a narrow-based security index if it would not be a narrow-based security index
if a futures contract on such index were traded on a designated contract market or registered
derivatives transaction execution facility.” CFTC Rule 41.13, 17 C.F.R. § 41.13; Exchange Act
Rule 3a55-3, 17 C.F.R. § 240.3a55-3
ex is traded on or subject to the rules of a foreign board of trade, such
index shall not be a narrow-based security index if it would not be a narrow-based security index
if a futures contract on such index were traded on a designated contract market or registered
derivatives transaction execution facility.” CFTC Rule 41.13, 17 C.F.R. § 41.13; Exchange Act
Rule 3a55-3, 17 C.F.R. § 240.3a55-3.

20 In making this determination, Commission staff has concluded that the RDXxt does not have
any of the elements of a narrow-based security index as enumerated in CEA Section 1a(25)(A),
and accordingly the RDXxt would not be a narrow-based security index if traded on a designated
contract market or DTEF.

5

In determining whether a foreign futures contract based on a foreign security index is not
readily susceptible to manipulation or being used to manipulate any underlying security, one
preliminary consideration is the requesting exchange’s ability to access information regarding
the securities underlying the index. All of the securities underlying the RDXxt are ADRs/GDRs
on Russian blue chip companies that are traded on the LSE’s IOB. Both the BaFin and the
United Kingdom’s (“U.K.’s”) regulator, the Financial Services Authority (“FSA”), are members
of the Committee of European Securities Regulators (“CESR”). Members of CESR have entered
into a Multilateral Memorandum of Understanding on the Exchange of Information and
Surveillance Activities that provides for sharing of certain market surveillance data among CESR
members. Both BaFin and the FSA also are signatories to the Multilateral Memorandum of
Understanding Concerning Consultation and Cooperation and the Exchange of Information of
the International Organization of Securities Commissions (“IOSCO MOU”). Moreover, the
BaFin entered into a bilateral information sharing memorandum of understanding (“MOU”) with
the Russian Federation’s regulator in 2001
mbers. Both BaFin and the FSA also are signatories to the Multilateral Memorandum of
Understanding Concerning Consultation and Cooperation and the Exchange of Information of
the International Organization of Securities Commissions (“IOSCO MOU”). Moreover, the
BaFin entered into a bilateral information sharing memorandum of understanding (“MOU”) with
the Russian Federation’s regulator in 2001. BaFin also entered into an MOU with the Russian
Federation’s Central Bank in 2006, the scope of which includes cooperation on “all violations of
law on financial markets.”21 Eurex may request that BaFin obtain information from the U.K. and
Russian regulators pursuant to these arrangements, as necessary, with regard to trading of the
ADRs/GDRs on the LSE and the underlying Russian equities, respectively. In addition, Eurex’s
Trading Surveillance Office is authorized under the German Exchange Act to obtain information
directly from, and share information directly with, similar trading surveillance offices of other
exchanges or regulators inside and outside of Germany.22

Through these arrangements, Eurex should have access to information necessary to detect
and deter manipulation. In the event that Eurex is unable to obtain access to adequate
surveillance data in this regard, or is unable, either directly or through the BaFin, to share such
data with the CFTC, this Office reserves the right to reconsider the position we have taken
herein.23

21 See electronic mail from Mr. Architzel to Mr. Hammar, dated September 10, 2007.

22 See letter from Mr. Architzel to Ms. Ritter, dated April 10, 2007, at 8 and electronic mail from
Mr. Architzel to Mr. Hammar, dated September 10, 2007.

23 Eurex has confirmed that it is willing and able to cooperate with the Commission through
information sharing and other means in relation to the trading of Eurex’s RDXxt futures contract.
See letter from Mr. Architzel to Ms. Ritter, dated April 10, 2007, at 8
Architzel to Ms. Ritter, dated April 10, 2007, at 8 and electronic mail from
Mr. Architzel to Mr. Hammar, dated September 10, 2007.

23 Eurex has confirmed that it is willing and able to cooperate with the Commission through
information sharing and other means in relation to the trading of Eurex’s RDXxt futures contract.
See letter from Mr. Architzel to Ms. Ritter, dated April 10, 2007, at 8. Eurex also is a signatory
to the International Information Sharing Memorandum of Understanding and Agreement signed
on March 15, 1996, at Boca Raton, Florida. Moreover, the BaFin’s predecessor, the BAWe, and
the CFTC entered into a Memorandum of Understanding concerning Consultation and
Cooperation in the Administration and Enforcement of Futures Laws on October 17, 1997. As
noted above, the BaFin is a signatory to the IOSCO MOU, to which the Commission also is a
signatory. In addition, the BaFin, through its predecessor, is a signatory to the Declaration on
Cooperation and Supervision of International Futures Exchanges and Clearing Organizations for
the sharing of large exposure information, signed on March 15, 1996, at Boca Raton, Florida.

6

In light of the foregoing, this Office will not recommend any enforcement action to the
Commission based on Sections 2(a)(1)(C)(iv), 4(a), or 12(e) of the CEA, as amended, if Eurex’s
futures contract based on the RDXxt is offered or sold in the U.S. Because this position is based
upon facts and representations contained in the letters, attachments, facsimiles and electronic
mail cited above, it should be noted that any different, omitted or changed facts or conditions
might require a different conclusion. This position also is contingent on the continued
compliance by Eurex with all regulatory requirements imposed by the BaFin, and the applicable
laws and regulations of Germany and the State of Hesse
ntained in the letters, attachments, facsimiles and electronic
mail cited above, it should be noted that any different, omitted or changed facts or conditions
might require a different conclusion. This position also is contingent on the continued
compliance by Eurex with all regulatory requirements imposed by the BaFin, and the applicable
laws and regulations of Germany and the State of Hesse. In addition, this position may be
affected by any rules that the Commission may adopt regarding futures contracts based on non-
narrow-based security indices.

Eurex also has requested that, upon issuance of the relief granted herein, it be permitted
to make the futures contract on the RDXxt available for trading through the electronic trading
terminals of its U.S. members in accordance with the terms of the August 10, 1999 foreign
terminals no-action letter, as amended (“August 10, 1999 letter”), issued by Commission staff to
Eurex.24 In this regard, Eurex has certified that it is in compliance with the terms of the August
10, 1999 letter and that Eurex’s futures contract on the RDXxt will be traded in accordance with
the terms and conditions of the August 10, 1999 letter.25 We have consulted with the
Commission’s Division of Market Oversight (“Division”), which is the Division in the
Commission that administers foreign terminal no-action letters. The Division has concluded that
allowing Eurex to make its futures contract on the RDXxt available for trading pursuant to the
August 10, 1999 letter would not be contrary to the public interest. Accordingly, on behalf of the
Division, this Office hereby confirms that the no-action relief granted to Eurex in the August 10,
1999 letter extends to Eurex’s futures contract on the RDXxt.26

24 See CFTC Staff Letter No. 99-48 [1999-2000 Transfer Binder] Comm. Fut. L. Rep. (CCH)
¶ 27,572 (Aug. 10, 1999).

25 See letter from Mr. Architzel to Ms. Ritter, dated April 10, 2007, at 14
n, this Office hereby confirms that the no-action relief granted to Eurex in the August 10,
1999 letter extends to Eurex’s futures contract on the RDXxt.26

24 See CFTC Staff Letter No. 99-48 [1999-2000 Transfer Binder] Comm. Fut. L. Rep. (CCH)
¶ 27,572 (Aug. 10, 1999).

25 See letter from Mr. Architzel to Ms. Ritter, dated April 10, 2007, at 14.

26 Please be advised that if Eurex intends to list options on its futures contract based on the
RDXxt, it may offer and sell those options in the U.S. with no further action from this Office, see
61 Fed. Reg. 10891 (March 18, 1996). However, if Eurex intends to make such options
available for trading via direct access from electronic trading terminals in the U.S., Eurex must
so notify the Division in accordance with the Notice of Revision of Commission Policy
Regarding the Listing of New Futures and Option Contracts by Foreign Boards of Trade That
Have Received Staff No-Action Relief to Provide Direct Access to Their Automated Trading
Systems From Locations in the United States, issued on April 18, 2006. See 71 Fed. Reg. 19877
(April 18, 2006).

7

The offer and sale in the U.S. of Eurex’s futures contract on the RDXxt is, of course,
subject to Part 30 of the Commission’s regulations, which governs the offer and sale of foreign
futures and foreign option contracts in the U.S.27

Sincerely,

Terry S. Arbit

General Counsel

27 See 17 C.F.R. Part 30.

8

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- [CFTC Letter No. 09-02 The Division of Clearing and Intermediary Oversight provided no-action relief to the general partner of a commodity pool from registering as a CPO under Section 4m(1) of the Commodity Exchange Act, and allowed an affi...](https://www.frixlaw.com/law-library/statutes/CFTC_L09_02.md)
- [CFTC Letter No. 09-06 The CPO of a commodity pool requested that DCIO agree to accept the Annual Report for the period from January 1, 2008 through October 31, 2008 as the Pool’s final annual report despite the fact that the Pool had not f...](https://www.frixlaw.com/law-library/statutes/CFTC_L09_06.md)
- [CFTC Letter No. 09-07 The CPO of a commodity pool with a de minimus amount of its assets embroiled in a bankruptcy requested relief from the ongoing reporting requirements under Part 4. The CPO filed an Annual Report for the Pool for the 2...](https://www.frixlaw.com/law-library/statutes/CFTC_L09_07.md)
- [CFTC Letter No. 09-11 The CPO of two commodity pools requested relief to use IFRS in lieu of US GAAP. DCIO granted relief pursuant to Commission Regulations 140.93 and 4.12(a).](https://www.frixlaw.com/law-library/statutes/CFTC_L09_11.md)
- [CFTC Letter No. 09-13 The CPO of commodity pool requested relief to use IFRS in lieu of US GAAP. DCIO granted relief pursuant to Commission Regulations 140.93 and 4.12(a).](https://www.frixlaw.com/law-library/statutes/CFTC_L09_13.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CFTC_L08_05. Check the current official text before relying on it. Not legal advice.