Kevin M. Foley

Kevin M. Foley

Katten Muchin Rosenman LLP

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NFA Issues Notice Regarding Changes to Form PQR and Form PR

On June 5, National Futures Association issued a notice to its members informing them that NFA has made several minor changes to the commodity pool operator Form PQR and commodity trading advisor Form PR...more

6/11/2014 - Commodities Commodity Broker Commodity Pool CPO Form PQR Form PR NFA

Corporate and Financial Weekly Digest - Volume IX, Issue 23

In this issue: - SEC Chair Gives Speech on Equity Market Structure - New CFTC Commissioners Confirmed; Chairman Sworn In - CFTC Extends No-Action Relief for Certain Transaction-Level Requirements...more

6/9/2014 - CFTC Commodity Pool CPO Cross-Border Derivatives Clearing Organizations Equity Markets Fraud NFA No-Action Relief SEC Swap Dealers Swaps

CFTC Staff Announces Streamlined No-Action Relief Process for Certain CPOs

On May 12, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight announced a streamlined process that will allow a commodity pool operator (CPO) that has delegated investment management...more

5/21/2014 - CFTC Commodity Pool CPO Financial Regulatory Reform No-Action Relief

Corporate and Financial Weekly Digest - Volume IX, Issue 20

In this issue: - Delaware Supreme Court Upholds Fee-Shifting Bylaw - FINRA Proposes Changes to FINRA Rules 7410 and 2121 - CFTC Staff Announces Streamlined No-Action Relief Process for Certain...more

5/19/2014 - CFTC Commodity Pool CPO Criminal Prosecution Fee-Shifting Statutes FINRA Fraud White Collar Crimes

CFTC Issues Advisory on Compliance with Gramm-Leach-Bliley Act Security Safeguards

On February 26, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission issued Advisory 14-21 to provide futures commission merchants, commodity trading advisors, commodity...more

3/4/2014 - CFTC Commodity Pool Compliance CPO DSIO Gramm-Leach-Blilely Act

NFA Requests Comment on CPO/CTA Requirements

National Futures Association (NFA) has requested comments from its commodity pool operator (CPO) and commodity trading advisor (CTA) members on whether to adopt capital requirements to ensure that CPOs and CTAs have adequate...more

1/29/2014 - Commodity Pool CPO CTA NFA

NFA Issues Guidance on Affirmation Process for CPO and CTA Exemptions and Exclusions

The National Futures Association (NFA) issued guidance on the annual affirmation requirement for persons operating under an exemption or exclusion from commodity pool operator (CPO) or commodity trading advisor (CTA)...more

12/11/2013 - CPO CTA Exclusions Exemptions NFA

CFTC Grants Relief to CPOs Trading Through Subsidiaries

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) has granted no-action relief from certain reporting obligations to commodity pool operators (CPOs) of registered investment...more

9/17/2013 - CFTC Controlled Foreign Corporations CPO DSIO Investment Funds No-Action Relief Subsidiaries

CFTC Adopts Final Harmonization Rules for Registered Investment Company Advisers Required to Register as CPOs Under Regulation...

On August 13, 2013, the Commodity Futures Trading Commission issued its final rules (“Final Rules”) applicable to registered investment companies now required to dually register as commodity pool operators (“Dually-Registered...more

8/21/2013 - CFTC Commodities Commodity Pool CPO CTA Investment Companies Registration SEC

NFA Amends CPO and CTA Quarterly Reporting Requirements

On April 24, the National Futures Association (NFA) issued a notice to members regarding amendments to NFA Compliance Rule 2-46. The amended rule modifies the NFA’s quarterly pool reporting requirements and extends related...more

4/30/2013 - Amended Regulation CFTC CPO CTA NFA Reporting Requirements

CFTC Staff Issues No-Action Letters

The Commodity Futures Trading Commission staff recently released a series of letters relating to a variety of regulatory issues, including registration relief for certain entities and recordkeeping requirements for certain...more

4/10/2013 - CFTC CPO Major Swap Participants No-Action Letters Recordkeeping Requirements Registration Swap Dealers Swaps

NFA to Require CPOs to Identify Registered Investment Companies

The National Futures Association (NFA) has notified its members that it will require each member of the NFA that is registered as a commodity pool operator (CPO) and operates one or more commodity pools that are also...more

2/6/2013 - CFTC CPO Investment Companies NFA Registration

Exemption from NFA Assessment Fee for Proprietary Trading Firms that Register as CPOs

The National Futures Association (NFA) has issued a notice temporarily exempting certain proprietary trading firms that may be required to be registered as commodity pool operators (CPOs) as of December 31, 2012, from the...more

12/28/2012 - CFTC CPO NFA

CFTC Issues No-Action Letters

The Commodity Futures Trading Commission (CFTC) released a series of staff letters relating to various issues arising under rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act, including chief...more

12/18/2012 - CFTC CPO Dodd-Frank FX Swaps No-Action Letters Swaps

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