No-Action Relief for CPO Registration

SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) requesting an extension of the time limited no-action relief for Commodity Pool Operators (CPO) registration in relation to securitization vehicles. The dialogue with market participants and industry representatives has been ongoing. In addition to pending questions raised about the characterization of particular structures, securitization market participants continue to be actively engaged in a dialogue with the CFTC Division of Swap Dealer and Intermediary Oversight (the Division) regarding the many respects in which the disclosures they mandate, actions they require or information they seek are problematic in the securitization context.  In light of the continuing discussions over these issues, including threshold issues that determine whether registration of a person as a CPO even would be required in respect of certain structures, SIFMA requests that the Division extend until September 30, 2013.