The No-Action Letter grants relief from required clearing under CEA Section 2(h)(1)(A) and CFTC Rules Part 50 (rules relating to clearing) for certain swaps entered into by qualifying cooperatives. To qualify for the No-Action Relief, one of the counterparties to the swap must be a cooperative, whose members are either non-financial entities or other cooperatives whose members are non-financial entities. See: CFTC Letter 13-30.

The SEC issued a No-Action Letter permitting a subadviser to deliver Form ADV Part 2 to an investment adviser with discretionary authority to manage a client's assets, or with authority to appoint one or more subadvisers to manage a client's assets, rather than requiring the subadviser to deliver Form ADV Part 2 directly to the end client. Such delivery is permitted where the client appoints the investment adviser to receive Form ADV Part 2 on the client's behalf, the client knows the identity of the subadviser, and the investment adviser has policies in place ensuring: adequate review of the

The Office of the Comptroller of the Currency (OCC) has issued a rule finalizing amendments to 12 CFR Part 32, which governs lending limits. The rule implementsDodd-Frank Section 610, which applies the lending limit statute to credit exposures arising from derivative transactions and securities financing transactions, and makes other changes. Effective Dates : Under the rule, a temporary exception period is extended for three months so that compliance with the Section 610 provisions will not be required until October 1, 2013. See: Final Rule Release.

The CFTC's Division of Swap Dealer and Intermediary Oversight (DSIO) announced the issuance of a No-Action Letter related to the fingerprinting requirement under CFTC Rule 3.12 for certain associated persons of CFTC registrants. The No-Action Letter responds to a request from the NFA for relief from the fingerprinting requirement for associated persons of CFTC registrants where the associated persons have not resided in the United States since reaching 18 years of age. The No-Action Letter provides that DSIO will not recommend that the CFTC commence an enforcement action against a sponsoring

The NFA announced an amendment to the Financial Requirements Section 1(a) to set forth an additional alternative minimum adjusted net capital requirement, of at least $20 million, that applies to an FCM that acts as a counterparty to a forex transaction with an eligible contract participant (ECP). All FCMs will be required to address questions in the Supplemental Schedule that they must file for June as to their forex transactions. See: NFA Announcement.