On December 19, 2014, the CFTC issued no-action relief to entities operating issuers of insurance-linked securities ("ILS Issuer") which exempt them from commodity pool operator registration, subject to certain conditions. To claim the relief, an operator of an ILS Issuer must file a notice of exemption with the National Futures Association pursuant to CFTC Regulation 4.13(b).
CFTC Staff Letter 12-152 is available at: http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14-152.pdf
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