The CFTC's Division of Swap Dealer and Intermediary Oversight (DSIO) issued the attached no-action letter that provides certain FCMs with limited relief regarding the requirement that chief compliance officers of such FCMs prepare and submit an annual report, pursuant to CFTC Rule 3.3, as to fiscal years ending by March 31, 2013. The relief provided in the no-action letter is applicable to all FCMs that: (1) were registered with the Commission as of June 4, 2012; and(2) are currently regulated by a U.S. prudential regulator or registered with the U.S. Securities and Exchange Commission

The SEC Division of Investment Management announced that it will no longer defer consideration of exemptive requests under the Investment Company Actrelating to actively-managed ETFs that make use of derivatives, provided that the ETFs include representations to address some of the concerns expressed in the March 2010 press release. These representations are as follows: (i) that the ETF's board periodically will review and approve the ETF's use of derivatives and how the ETF's investment adviser assesses and manages risk with respect to the ETF's use of derivatives; and (ii) that the ETF's

FINRA provided the attached schedule to assist member firms and reduce the number of Reg T and Exchange Act Rule 15c3-3 extensions denied around holidays. Click here to view notice in full (links externally to FINRA website).

Continuing our efforts to provide a unified source of current and proposed rules and interpretations, along with our analysis and practical guidance, we are pleased that The Cadwalader Cabinet now makes available a comprehensive library of materials for CPOs and CTAs. How cool is that?! (Pretty reasonably cool as far as things done by lawyers go!) These materials include: A Guide to CPO/CTA Regulation, with updated chapters on registration requirements and insolvency; Our industry-model CPO/CTA Compliance and Supervisory Procedures Manual; The CEA, CFTCand NFA Rules and related materials in an

CME Group, Futures Industry Association (FIA), the Institute for Financial Markets and NFA announced that they have jointly commissioned a firm to study the costs and benefits of adopting an insurance regime for the U.S. futures industry. The study (due out in the spring) will examine various models for providing insurance in the futures industry and assess a range of variables for each model, and is expected to address a lack of detailed information on the potential costs and benefits associated with various insurance alternatives. This insurance study is the latest in a series of initiatives