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December 12, 2025
Cadwalader assisted the Structured Finance Association (SFA) with drafting and obtaining the CFTC Staff Letter No. 25-37, Nov. 2025, a no-action letter that is a significant regulatory development for the structured finance and banking sectors.
This letter provides critical relief to banks issuing Credit Risk Transfers (CRTs) by clarifying that operators of special purpose vehicles (SPVs) used in qualifying CRT transactions do not need to register as Commodity Pool Operators (CPOs) and can rely on a de minimis pool registration exemption under Sec 4.13(a)(3) of CFTC Regulations.
The Cadwalader team was led by Peter Malyshev in conjunction with Jed Miller and Ivan Loncar.
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