As a reminder, pursuant to an Interpretive Notice recently released by the National Futures Association (“NFA”), all commodity pool operators (“CPOs”) that are registered with the U.S. Commodity Futures Trading Commission...more
The National Futures Association recently amended NFA Compliance Rule 2-46 in order to impose late fees for its commodity pool operator (CPO) and commodity trading adviser (CTA) members that do not make quarterly filings on...more
As a reminder, fund managers relying on the exemption from registration with the US Commodity Futures Trading Commission (the “CFTC”) set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...more
Proficiency Requirements for Security Futures Products -
The term security futures product (“SFP”) encompasses security futures and options on security futures. The term security future includes both futures on a single...more
The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (the “CFTC”) recently issued answers to Frequently Asked Questions (“FAQs”) regarding CFTC Form CPO-PQR applicable to...more