On December 19 2014 the Commodity Futures Trading Commission (CFTC) issued no-action relief to entities operating issuers of insurance-linked securities (ILS issuers) which exempts them from commodity pool operator registration, subject to certain conditions. To claim the relief, an operator of an ILS issuer must file a notice of exemption with the National Futures Association pursuant to CFTC Regulation 4.13(b).
CFTC Staff Letter 12-152 is available at www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14-152.pdf.
Donna M Parisi
Geoffrey B Goldman
Azam H Aziz
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