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In its last regulatory action for 2022, on December 23, the U.S. Commodity Futures Trading Commission (“CFTC”) published its staff no-action letter No. 22-21 (“NAL”) allowing commodity brokers – Futures Commission Merchants (“FCMs”) – to invest their customer funds in investment instruments that contain an adjustable rate of interest that is benchmarked to Secured Overnight Financial Rate (“SOFR”) instead of London Interbank Offered Rate (“LIBOR”). This NAL expanded CFTC’s previous similar relief to also apply to Derivatives Clearing Organizations (“DCOs”) investing customer funds.  https://www.cadwalader.com/resources/articles/latest-cftc-action-on-libor-transition