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CFTC Finalizes Rule 4.7 Amendments, Defers Key Disclosure Requirements

The CFTC has finalized portions of its proposed October 2023 amendments to CFTC Rule 4.7. The CFTC moved forward on: Raising the thresholds for qualification of certain investors in private funds commodity pool operators...more

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

CFTC Proposes Significant Disclosure Requirements with which CPOs and CTAs Operating under CFTC Rule 4.7 Will Have to Grapple

The Commodity Futures Trading Commission (Commission or CFTC) voted to announce proposed rule changes on October 2, 2023, that would significantly change the disclosure requirements applicable to registered commodity pool...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

CFTC Finalizes New Requirement Applying Statutory Disqualification Prohibitions to CPOs Exempt under CFTC Regulation 4.13 – Exempt...

CFTC Also Proposes Amendments to Help Non-U.S. CPOs and Extends its Uncleared Swap Margin Phase-In Schedule - During the period from late May 2020 through early June 2020, the Commodity Futures Trading Commission held...more

CFTC and NFA Issue Relief for Registered CPOs and CTAs in Response to Disruptions Caused by COVID-19 Coronavirus Pandemic

The Commodity Futures Trading Commission issued industry-wide no-action relief for registered commodity pool operators on March 20, 2020, to permit those CPOs additional time to make certain regulatory filings and issue...more

New NFA Filing Obligations for Investment Advisers to BDCs Trading Commodity Interests Require Action as Soon as Practicable After...

The Commodity Futures Trading Commission published in the Federal Register on December 10, 20191 amendments to five different aspects of the regulatory framework applicable to certain commodity pool operators (CPOs) and...more

New CFTC DSIO Director Outlines Components of Regulatory Program Applicable to Asset Managers; Addresses Extension of the CFTC...

Director Joshua B. Sterling of the CFTC’s Division of Swap Dealer and Intermediary Oversight (DSIO or Division) delivered several speeches in September and early October 2019, setting forth certain guiding principles and the...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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