CFTCs Second Letter Clarifies Commodity Pool Treatment for Certain Securitizations, Provides Relief
December 14, 2012
The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission has issued an interpretation clarifying commodity pool treatment for certain securitizations and a no-action letter providing additional relief for certain legacy securitization entities. Specifically, the letter explains when exclusion from commodity pool regulation for certain securitization vehicles that do not meet any of the criteria set forth in an October 2012 no-action letter is appropriate. It also provides relief for certain securitization vehicles formed before Oct. 12, 2012. In the October no-action letter, the CFTC spelled out...