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28 January 2015
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.
For further information on this topic please contact Donna M Parisi, Geoffrey B Goldman or Azam H Aziz at Shearman & Sterling LLP by telephone (+1 212 848 4000), fax (+1 212 848 7179) or email (firstname.lastname@example.org, email@example.com or firstname.lastname@example.org). The Shearman & Sterling website can be accessed at www.shearman.com.
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