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Registered CPOs and CTAs Must Take Action with NFA by October 2024

Pursuant to new National Futures Association (NFA) Compliance Rule 2-52, Interpretive Notice 9082 and amendments to NFA Bylaw 301, for NFA membership filings, membership renewals and material updates made after October 15,...more

NFA Institutes New Operational Requirements for Members; Registered CPOs and CTAs Need to Take Action in Q3 and Q4 2021

The National Futures Association has adopted two new operational requirements that will affect (among others) registered commodity pool operators and commodity trading advisors. Under new NFA Compliance Rule 2-50, as of...more

CFTC Broadens Available Exemption for Non-U.S. CPOs

The Commodity Futures Trading Commission, on December 7, 2020, published in the Federal Register significant amendments to CFTC Regulation 3.10(c) (Amendments), making the regulation a more broadly available registration...more

Registered and Exempt Market Participants May Need to Plan Ahead to Take Action Early in 2021 to Address CFTC and NFA Rule and...

During the course of 2019 and 2020, the Commodity Futures Trading Commission and the National Futures Association (NFA, the self-regulatory organization for the U.S. futures and swaps industry) have been hard at work amending...more

CFTC Proposes Changes to Form CPO-PQR

The Commodity Futures Trading Commission published on April 14, 2020, a proposal to amend certain compliance requirements for commodity pool operators under CFTC Rule 4.27 and CFTC Form CPO-PQR, as codified at Appendix A to...more

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - January 2019

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

CFTC Proposes Amendments to Regulatory Framework for Certain CPOs and CTAs and New Exemption for CPOs of Non-U.S. Pools

The Commodity Futures Trading Commission issued a Notice of Proposed Rulemaking on October 9, 2018 to amend certain aspects of the current regulatory framework applicable to commodity pool operators (CPOs) and commodity...more

Registered CPOs and CTAs: Prepare for June 30 Changes to NFA Forms PQR and PR

Beginning with the second quarter 2017 filings, registered commodity pool operators (CPOs) and commodity trading advisors (CTAs) (collectively, Registrants) will need to report financial information regarding their own...more

CFTC Staff Issues No-Action Relief Helpful for Non-U.S. Commodity Pool Operators and Commodity Trading Advisors

The U.S. Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) provided no-action relief on February 12, 2016 to commodity pool operators (CPOs) and commodity trading advisors...more

NFA Adopts Cybersecurity Guidance

The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

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