On July 13, 2012, the Division of Swap Dealer and Intermediary Oversight (the Division) of the U.S. Commodity Futures Trading Commission (CFTC) issued a no-action letter in response to the requests of several industry trade associations that the CFTC (i) delay the compliance date for including swaps as "commodity interests" when determining compliance with CFTC Rules 4.13(a)(3) and 4.5, and (ii) grant temporary relief from CFTC registration to commodity pool operators (CPOs) and commodity trading advisers (CTAs) who would have been exempt under Rule 4.13(a)(4) or Rule 4.5 but for the February amendments. Although the first request was denied, the Division agreed that eligible CPOs and CTAs will not be subject to CFTC enforcement action for failure to register as a CPO and/or a CTA before December 31, 2012.

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