Family Office Relief from CPO Registration

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As noted in an earlier Client bulletin, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued a no-action letter dated November 29, 2012 enabling family offices to claim an exemption from registration as a commodity pool operator.  In order to obtain such relief, the family office was required to file the claim electronically before December 31, 2012.
Additionally, any family office making such claim of exemption must, prior to March 31, 2013, file electronically with the CFTC a confirmation that (a) it is a “family office” within the meaning of the Security and Exchange Commission’s definition set forth in its Rule 202(a)(11)(G)-1 and (b) that it will notify the Division if it should cease to be a family office as defined by the SEC.
Consequently, family offices previously claiming the exemption provided in the no-action letter should ensure that the confirmation as to family office status be filed not later than March 31, 2013.
If you have any questions, please contact Scott McGinness or any other member of Miller & Martin's Investment Management Practice Group.

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CPO
SEC

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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