M. Holland West

M. Holland West

Dechert LLP

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CFTC Permits Additional Third-Party Recordkeepers for Registered CPOs

The Division of Swap Dealer and Intermediary Oversight (DSIO Staff) of the U.S. Commodity Futures Trading Commission (CFTC) issued exemptive relief on September 8, 2014 to permit a registered commodity pool operator (CPO) to...more

9/16/2014 - CFTC CPO Recordkeeping Requirements SEC Swap Dealers Third-Party Service Provider

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 Companies Investment Company Act of 1940

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

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