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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

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

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

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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