The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) has issued exemptive relief to commodity trading advisors (CTAs) from the requirement to keep records under CFTC Regulations 4.7(c)(2) and 4.33 at the CTA’s main business office. As provided in the exemptive letter, a CTA may use a third-party recordkeeper so long as the CTA files a notice of claim with the DSIO containing the representations set forth in the exemptive letter. The notice of claim must be filed at the time the CTA registers with the CFTC, delegates its recordkeeping obligations, or June 30, 2017, whichever is later.
CFTC Letter No. 17-24 is available here.
In September 2014, DSIO granted similar relief to commodity pool operators, which is available here.