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Questions & Answers on State and Local Variations on the SEC Pay-to-Play Rule

Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more

Pennsylvania Treasurer Prohibition on Third-Party Placement Agents

The Treasurer of the Commonwealth of Pennsylvania has prohibited investment managers from using third-party placement agents for funds managed on behalf of the Commonwealth of Pennsylvania Treasury Department. The Treasury...more

CFTC Permits Unaudited Financial Statements Upon Liquidation of a Series of a Pool That is Also a Registered Investment Company

The Commodity Futures Trading Commission (“CFTC” or “Commission”) has provided general exemptive relief to persons registered as commodity pool operators (“CPO”) under the Commodity Exchange Act that operate commodity pools...more

SEC Adopts Rules for Reporting Separately Managed Accounts on Form ADV and Revised Recordkeeping Rules

Amendments to Form ADV - Information Regarding Separately Managed Accounts - The SEC’s final amendments to Part 1A of Form ADV include items intended to collect more information about each adviser’s SMAs. The...more

New California Law Mandating Disclosure of Certain Fees and Expenses

The California Government Code has been amended to require additional public disclosure about investments by state or local California public pension plans (the “California Plans”). The amendment, which is the most...more

Better Late Than Never? The CFTC and the NFA Publish FAQs on CPO and CTA Reporting Forms

On November 5, 2015, the Commodity Futures Trading Commission (“CFTC”) Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued responses to frequently asked questions (“CFTC FAQs”) regarding CFTC Forms CPO-PQR and...more

12/1/2015  /  CFTC , CPOs , Form PQR , New Guidance , NFA

SEC Proposes Rules for Reporting Separately Managed Accounts on Form ADV and Revised Recordkeeping Rules

On May 20, 2015, the U.S. Securities and Exchange Commission (“SEC”) proposed amendments to Part 1A of Form ADV in three areas: to collect information regarding separately managed accounts (“SMAs”) and additional information...more

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

CFTC Clarifies and Expands Relief Relating to Delegation of Commodity Pool Operator Responsibilities

On October 15, 2014, the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (“CFTC” or “Commission”) issued CFTC No-Action Letter No. 14-126 (“Letter 14-126”),...more

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

NFA Seeks Comment on Capital Requirements for CPOs and CTAs

National Futures Association (NFA), the industry-funded self-regulatory for the futures industry, issued a Notice to Members (Notice) on January 23, 2014, requesting comment on the concept of imposing a capital requirement on...more

1/31/2014  /  Capital Requirements , CPO , CTA , NFA , Public Comment

Questions & Answers on State and Local Variations on SEC Pay-to-Play Rule

Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more

CFTC Adopts Harmonization Rules for Investment Advisers that are Commodity Pool Operators of Registered Funds

On August 13, 2013, the Commodity Futures Trading Commission (“CFTC”) adopted long-awaited harmonization rules (“Harmonization Rules”) for operators of registered investment companies (“Registered Funds”) that are subject to...more

CFTC Classifies Certain Securitization Vehicles as Not Being Commodity Pools

Recent changes to the commodity pool regulations under the Commodity Exchange Act (the “CEA”) may subject certain securitization transactions and their managers to regulation by the Commodity Futures Trading Commission (the...more

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

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