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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 and NFA Announce Changes in Regulation Regarding Position Limits and Virtual Currency

Introduction - The Commodity Futures Trading Commission (“CFTC”), the U.S. federal regulatory agency for futures and other derivatives, and the National Futures Association (“NFA”), the industry-wide self-regulatory...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

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