Kevin M. Foley

Kevin M. Foley

Katten Muchin Rosenman LLP

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CFTC Issues Relief From IB and CTA Registration to Foreign Persons Dealing in Swaps for International Financial Institutions

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from introducing broker (IB) and commodity trading advisor (CTA) registration to persons...more

6/17/2015 - CFTC CTA DSIO Financial Institutions Foreign Banks Introducing Brokers No-Action Relief Swap Dealers Swaps World Bank

NFA Issues Guidance on Exempt and Excluded CPOs and CTAs

On December 3, National Futures Association (NFA) issued guidance reminding firms that are relying on certain exemptions or exclusions from registration as commodity pool operators (CPOs) or commodity trading advisors (CTAs)...more

12/10/2014 - CPOs CTA Exemptions National Futures Association New Guidance Registration

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

CFTC Extends Relief from Oral Communication Recording Requirement

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight issued No-Action Letter No. 13-77, which extends the oral communications recording compliance...more

1/8/2014 - Audio Recording CFTC CTA No-Action Letters Oral Communications SEFs

CFTC Issues Advisory Concerning Commodity Trading Advisors and Swaps

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued Advisory No. 13-79 to provide guidance to commodity trading advisors (CTAs) on new obligations relating to swaps...more

1/8/2014 - CFTC CTA DSIO Swaps

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

NFA Commences New Filing Requirement for Commodity Trading Advisors

On September 16, the National Futures Association (NFA) issued a notice to inform its members that NFA’s new quarterly reporting requirement for commodity trading advisor (CTA) member firms pursuant to NFA Compliance Rule...more

9/25/2013 - CTA Filing Requirements New Regulations NFA

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

CFTC Grants Relief to CTAs and IAs from Swap Block Trade Aggregation Prohibition

The Commodity Futures Trading Commission’s Division of Market Oversight has issued no-action relief from the prohibition in CFTC Regulation 43.6(h)(6) on the aggregation of orders for different accounts to satisfy minimum...more

8/7/2013 - Block Trades CFTC CTA Investment Adviser No-Action Relief Swaps

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

NFA Issues Notice Regarding CTA Reporting Requirements

National Futures Association (NFA) issued a notice to members relating to reporting requirements for commodity trading advisors (CTAs)...more

1/31/2013 - Commodities CTA Investment Adviser NFA Reporting Requirements

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