Key takeaways:

In two no-action letters dated December 21, 2012, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission provides no action relief to:

• Investment pools that invested in certain legacy securitization vehicles formed before October 12, 2012 whose operators are entitled to no-action relief under the terms of CFTC Staff Letter 12-45; and
• Certain commodity pool operators, commodity trading advisors, or principals or associated persons thereof whose timely registration application with the National Futures Association is pending.