Highlights From Recent CFTC Guidance On ILS Registration
Law360, New York (January 7, 2015, 10:30 AM EST) -- On Dec. 18, 2014, the U.S. Commodity Futures Trading Commission issued a no-action letter (CFTC Letter 14-152) providing relief from commodity pool operator (CPO) registration for operators of certain insurance-linked securities (ILS) issuers. As a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and CFTC regulations promulgated thereunder, there had been some uncertainty as to whether an ILS issuer could fall within the newly expanded definition of "commodity pool" to the extent that the underlying risk transfer contract could be considered a "swap." The CFTC no-action letter was issued in response to a Securities Industry and Financial Markets Association request that was formally made in August 2014 after many months of discussions with the staff of the CFTC....
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