CFTC Staff Delays Registration Deadline for Certain Fund of Fund Operators


On November 30, 2012, the CFTC staff published relief for fund of fund operators who would otherwise be required to register with the CFTC as commodity pool operators by December 31, 2012 but do not have access to information from the funds in which they invest necessary to determine whether registration is required. The relief delays the registration date for such persons until the later of June 30, 2013 or six months from the date the staff issues revised guidance (or the compliance date, if later) on the application of the de minimis thresholds in the context of Rules 4.5 and 4.13(a)(3). A filing by the operator with the CFTC in respect of a fund of funds must be made to claim this no-action relief, which will be effective upon receipt. The relief is available to fund of fund operators who meet the following conditions...

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