On November 26, 2014, the CFTC issued a no-action letter modifying relief that was previously issued for treasury affiliates in June 2013 in CFTC No-Action Letter 13-22. Similar to No-Action Letter 13-22, this letter provides relief from required clearing for “eligible treasury affiliates” that are wholly owned by a non-financial parent company and are defined as “financial entities” under the Commodity Exchange Act, due to the activities undertaken on behalf of its non-financial affiliates. The new letter makes several changes to the June 2013 letter, including amendments to requirements imposed on operations between a treasury affiliate and its affiliates, removal of restrictions as to the number of financial affiliates that may be within a corporate group and permission for treasury entities affiliated with non-bank financial companies designated as systemically important to elect relief subject to certain conditions.

CFTC Staff Letter 14-144 is available at: