On August 5th, the CFTC published its no-action letter providing temporary, relief from certain self-effectuating provisions of the Dodd-Frank Act and the Commodity Exchange Act ("CEA") that otherwise would have taken effect on July 16, 2011, but that require further definition and may not be eligible for the exemptive relief provided by the order issued by the CFTC on July 14, 2011 pursuant to Section 4(c) of the CEA. The no-action relief will expire automatically upon the earlier of the effective date of the applicable final rules defining the relevant terms or December 31, 2011 and does not affect any Dodd-Frank Act implementing regulations promulgated by the CFTC or the applicability of any provision of the CEA to futures contracts or options on futures contracts or to cash markets.