News & Analysis as of September 20, 2024

No-Action Letters

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A Commodity Pool is an investment structure or enterprise where funds from a number of participants are combined into a single entity for the purpose of trading futures contracts, options on contracts, retail... more +

Customer Segregation: Keep It Separate

CFTC Codifies Registration and Reporting Relief for Commodity Pool Operators and Commodity Trading Advisors

Cadwalader, Wickersham & Taft LLP on 1/17/2020

The Commodity Futures Trading Commission (the “CFTC”) approved the publication of two releases (the “Final Rules”) on November 25, 2019, adopting final amendments to Part 4 of the CFTC Rules which codify and expand a number...more

CFTC Proposes Amendments to Regulatory Framework for Certain CPOs and CTAs and New Exemption for CPOs of Non-U.S. Pools

Dechert LLP on 11/7/2018

The Commodity Futures Trading Commission issued a Notice of Proposed Rulemaking on October 9, 2018 to amend certain aspects of the current regulatory framework applicable to commodity pool operators (CPOs) and commodity...more

Orrick's Derivatives in Review - July 2014

Orrick, Herrington & Sutcliffe LLP on 7/3/2014

Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more

NFA Requires Notice Filing from Registered Fund CPOs Reporting on a Consolidated Basis for Registered Fund Pools and Their...

Goodwin on 11/21/2013

The National Futures Association (the “NFA”) issued Notice to Members I-13-36 (the “NFA Notice”) which is directed at any commodity pool operator (“CPO”) of a registered investment company (a “RIC”) that has filed a notice...more

Corporate and Financial Weekly Digest - October 4, 2013

Katten Muchin Rosenman LLP on 10/7/2013

In this issue: - FINRA Proposes Rule to Require Alternative Trading Systems to Report Volume Information and Use Unique Market Participant Identifiers - SEC Issues Frequently Asked Questions Regarding Liability...more

CFTC No Action Letter for Controlled Foreign Corporations

Orrick - Finance 20/20 on 9/11/2013

On September 5, the CFTC issued a no-action letter to commodity pool operators of registered funds that trade in commodity interest through wholly-owned controlled foreign corporations (CFCs)....more

Orrick's Financial Industry Week in Review - September 9, 2013

Orrick, Herrington & Sutcliffe LLP on 9/10/2013

Agency Template for Tailored Resolution Plans - On September 3, the FDIC and the Fed released an optional model template for tailored resolution plans required to be submitted by the Dodd-Frank Act. SEC Risk...more

Family Office Relief from CPO Registration

Miller & Martin PLLC on 2/26/2013

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...more

"CFTC Staff Provides Mortgage REITs With No-Action Relief From Commodity Pool Operator Registration"

Skadden, Arps, Slate, Meagher & Flom LLP on 12/13/2012

On December 7, 2012, the Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) issued no-action relief from commodity pool operator (CPO) registration to mortgage REITs that...more

CFTC No-Action Relief for CPO Registration of Business Development Companies

Orrick - Finance 20/20 on 12/10/2012

On December 4, the CFTC issued a no-action letter stating that the Division of Swap Dealer and Intermediary Oversight will not take enforcement action against operators of business development companies for failure to...more

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