SFA Member Alert: SFA Member Alert: CFTC Issues CPO No-Action Letter

Published on November 25, 2025

SFA Member Alert: CFTC Issues CPO No-Action Letter

On November 21, the Commodity Futures Trading Commission issued a no-action letter to the

Structured Finance Association. In response to SFA’s previous advocacy, the CFTC’s letter provides relief from commodity pool operator (CPO) registration and certain compliance requirements for banks setting up or operating the special purpose vehicles (SPVs) in certain CRT transactions.

If you would like to join SFA’s CFTC Regulatory Review Task Force, please fill out this join form.* For more information, please email SFA Committees.

Join the CFTC Regulatory Review Task Force

*Please note that participation in SFA Committees and Task Forces is limited to SFA members.