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CFTC and SEC Issue Privacy Guidance

CFTC Proposes New Swap Data Reporting Requirements and NFA Proposes Dues Surcharge for Swap Firms - INTRODUCTION - The Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”)...more

Swaps Proficiency Requirements for Associated Persons; Revised Form 7-R

Introduction - By a Notice to Members dated March 25, 2019, the National Futures Association (“NFA”), the self-regulatory organization for the U.S. derivatives industry, announced that it had amended rules and adopted an...more

NFA Proposes Interpretive Notice Addressing CPO Internal Controls

Introduction - By letter dated December 10, 2018, the National Futures Association (“NFA”), the self-regulatory organization for the U.S. derivatives industry, submitted to the U.S. Commodity Futures Trading Commission...more

CFTC Proposes to Codify Relief for CPOs and CTAs

Introduction - The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) is proposing amendments to its regulations governing commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) to codify...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

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 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

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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