Key takeaways

• The Division of Swap Dealer and Intermediary Oversight of the CFTC issued a no-action letter granting relief from commodity pool operator registration for entities engaging in insurance-linked securities transactions, subject to certain conditions. The relief was granted in response to a letter from the Securities Industry and Financial Markets Association.
• The relief allows operators of entities engaging in such transactions not to register as a commodity pool operator if they satisfy the conditions of the de minimis exemption in CFTC regulation 4.13(a)(3) and certain other conditions set forth in the no-action letter.