Carolyn A. Jayne

Carolyn A. Jayne

K&L Gates LLP

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NFA Requires Delegated CPOs to Identify Themselves

The National Futures Association (“NFA”) issued a Notice to Members on April 8, 2015 that requires “Delegated CPOs” to identify themselves as such when filing a commodity pool’s annual financial statement. Registered...more

4/13/2015 - CFTC CPOs Delegated CPOs FCMs Financial Statements National Futures Association

CFTC Provides Streamlined No-Action Relief Filing Procedure to Certain Commodity Pool Operators Who Delegate Responsibilities to...

The Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (“CFTC” or the “Commission”) recently issued CFTC Letter No. 14-69 (May 12, 2014) (the “Letter”), which...more

6/9/2014 - CFTC Commodities Commodity Pool CPO No-Action Relief SEC Swap Dealers Swaps

SEC Adopts Rule Amendments to Permit General Solicitation in Certain Private Offerings

On July 10, 2013, the Securities and Exchange Commission (“SEC”) adopted final rules to eliminate the prohibition against general solicitation and general advertising in certain securities offerings under Rule 506 of...more

7/19/2013 - Advertising General Solicitation JOBS Act Private Placements Regulation D Rule 144A Rule 506 Offerings SEC Securities Act of 1933

NFA Issues Guidance on Reaffirmation of CPO/CTA Exemptions

Introduction - Earlier this year, the Commodity Futures Trading Commission (“CFTC”) promulgated amendments to its regulations governing commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) that now...more

12/13/2012 - CFTC Commodity Pool CPO CTA Dodd-Frank NFA

CFTC Provides Relief from CPO Registration to Certain Family Offices

Introduction The Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (“CFTC” or “Commission”) recently issued CFTC Letter No. 12-37 (November 29, 2012), which...more

12/10/2012 - CFTC CPO Family Offices

CFTC Extends Compliance Date for Operators of Funds of Funds

Background - At the request of the Investment Adviser Association and the Managed Funds Association, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission...more

12/6/2012 - CFTC Commodity Pool Investment Adviser Swaps

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