CFTC Swap No-Action Relief for Registration and Compliance

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On July 13, the CFTC announced time-limited no-action relief for commodity pool operators (CPOs) and commodity trading advisors (CTAs) who have been exempt or excluded from registration but, because of recent amendments to Commission Regulations 4.13 and 4.5, now need to register and satisfy compliance obligations. Under the relief, the CFTC will not take will not take enforcement actions against CPOs or CTAs for failure to register until December 31, subject to satisfaction of requirements including filing of a notice. CFTC Release.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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