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
- 401k CFTC Commodity Pool CPO NFA Participant-Directed Plans Retirement Plan
Much of the investment capital in the U.S. market is in retirement plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). Over the years, an important element of a number of plans’ investment...more
- Derivatives Dodd-Frank DOL ERISA Fiduciary Duty INHAM QPAM Swaps
The U.S. Department of Labor (the “DOL”) recently issued an information letter, dated November 9, 2012 (the “Information Letter”), in which it confirms that, for all purposes of determining what parties are “related” to a...more
- Asset Management DOL ERISA
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