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2014-15 Compliance Developments & Calendar for Private Fund Advisers

Introduction - Registered investment advisers are required to review their policies and procedures on at least an annual basis. As aid to the required review, below is a summary of material developments during the past...more

10/6/2014 - Affiliates AIFMD Broken Windows Chief Compliance Officers CPO Cybersecurity Export Controls FATCA Foreign Affiliates Foreign Investment General Solicitation Investment Adviser Policies and Procedures Private Funds Proxy Voting Guidelines Reporting Requirements SEC Social Media Policy

CFTC Publishes Long-Awaited JOBS Act Relief

The staff of the Commodity Futures Trading Commission (CFTC) published a no-action letter on September 9, 2014 (available here) that permits certain commodity pool operators (CPOs) to conduct general solicitation in private...more

9/12/2014 - CFTC CPO Disclosure Requirements Exemptions General Solicitation JOBS Act No-Action Letters Private Offerings Reporting Requirements Rule Rule 144A Rule 506(c) SEC

CFTC Staff Announces Streamlined Process for CPO Delegation

On March 12, 2014, the Commodity Futures Trading Commission (CFTC) staff issued the long-awaited guidance letter relating to the delegation of commodity pool operator (CPO) functions from persons that might otherwise be...more

5/15/2014 - CFTC CPO No-Action Letters No-Action Relief

CFTC Amends Certain Record Retention and Document Distribution Requirements for All CPOs and CTAs

On August 13, 2013, the Commodity Futures Trading Commission (CFTC) adopted amendments to certain provisions of Part 4 of the CFTC regulations that are applicable to all commodity pool operators (CPOs) and commodity trading...more

8/21/2013 - CFTC Commodity Pool CPO CTA Disclosure Requirements Distribution Rules Documentation Investment Company Act of 1940 Recordkeeping Requirements RICs SEC

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