M. Holland West

M. Holland West

Dechert LLP

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CFTC Staff Issues Self-Executing CPO Delegation Relief

The staff of the Commodity Futures Trading Commission (CFTC Staff) on October 15, 2014 simplified the process for a natural person or entity that the CFTC considers to be a commodity pool operator (CPO) to delegate its CPO...more

10/21/2014 - CFTC Commodities Commodity Pool Compliance CPOs

CFTC Adopts New CPO Rules for Registered Investment Companies and Others

Introduction - The U.S. Commodity Futures Trading Commission (“CFTC”) recently released its long-awaited “Final Rule” to harmonize CFTC disclosure, reporting, and recordkeeping requirements with parallel U.S....more

10/7/2013 - CFTC Commodity Pool CPO International Harmonization Investment Company Act of 1940 Investment Corporations

401(k) Plans—Potential Commodity Pool Issues in the United States

Under the rules of the Commodity Futures Trading Commission (“CFTC”), certain collective investment vehicles and other entities that, directly or indirectly, invest in “commodity interests” may be “commodity pools” whose...more

2/28/2013 - 401k CFTC Commodity Pool CPO NFA Participant-Directed Plans Retirement Plan

CFTC Issues Broad Securitization Industry Relief on Commodity Pool Regulation

On Friday, December 7, 2012, the U.S. Commodity Futures Trading Commission (CFTC), through its Division of Swap Dealer and Intermediary Oversight (Division), issued a letter which provides broad relief for certain segments of...more

12/13/2012 - CFTC Commodity Pool No-Action Relief Securitization Vehicles Swap Dealers

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