Cary J. Meer

Cary J. Meer

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 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

10/20/2014 - CFTC CPOs Delegation Clauses No-Action Letters Registration

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

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

8/28/2013 - CFTC CPO Disclosure Requirements Harmonization Rules Investment Adviser NFA Recordkeeping Requirements Registered Funds SEC

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

12/24/2012 - CEA CFTC Commodity Pool Securitization Vehicles

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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