Nhung Pham

Nhung Pham

Shearman & Sterling LLP

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CFTC Staff Issues Revised No-Action Relief from CPO Registration for Certain Delegating CPOs

On October 15, 2014, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the US Commodity Futures Trading Commission (“CFTC”) issued a no-action letter (“Letter 14-126”)1 providing conditional relief from...more

10/20/2014 - CFTC CPOs Delegation Clauses No-Action Relief Registration

CFTC Staff Issues Exemptive Letter Facilitating Broader Marketing of Certain Commodity Pools

On September 9, 2014, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the US Commodity Futures Trading Commission (“CFTC”) issued an exemptive letter (“Letter”) harmonizing certain CFTC restrictions on...more

9/22/2014 - Advertising CFTC CPO General Solicitation JOBS Act Opinion Letter Regulation D Rule 506(c)

CFTC Adopts Harmonization Rules for CPOs of Registered Investment Companies

The US Commodity Futures Trading Commission (“CFTC”) has adopted widely anticipated rules regarding the application of its commodity pool operator (“CPO”) regulatory regime to CPOs of registered investment companies...more

8/23/2013 - CFTC CPO International Harmonization Investment Funds Registration

CFTC Swap Reporting No-Action Relief Granted; Other Dodd-Frank Deadlines Approaching

On April 9, 2013, the US Commodity Futures Trading Commission (the “CFTC”) granted last minute no-action relief from portions of the CFTC’s swap reporting rules. The relief delays certain compliance deadlines for many swap...more

4/15/2013 - CFTC Dodd-Frank No-Action Relief Reporting Requirements Swaps

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