News & Analysis as of

Commodity Pool Commodity Trading Advisors (CTAs) No-Action Relief

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 +
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 off-exchange forex contracts or swaps, or to invest in another commodity pool.   less -
Proskauer Rose LLP

CFTC Adopts Final Rules Clarifying CPO and CTA Exemptions for Family Offices, BDCs

Proskauer Rose LLP on

On November 25, 2019, the Commodity Futures Trading Commission (CFTC) approved final rule amendments intended to simplify certain existing CFTC rules, codify certain previously granted no-action relief, and better coordinate...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Proposes to Simplify, Modernize Commodity Pool Operator and Commodity Trading Advisor Regulations

On October 18, 2018, the Commodity Futures Trading Commission (CFTC) published a proposal in the Federal Register (Proposed Rule) to amend several key compliance and registration regulations governing commodity pool operators...more

Morgan Lewis

CFTC Proposes Permanent Registration Relief to Certain Non-US Asset Managers

Morgan Lewis on

The amendments to the CFTC’s registration rules will codify no-action relief that permits non-US asset managers to rely on an exemption from the requirement to register with the CFTC by virtue of trading uncleared swaps in...more

Morgan Lewis

CFTC Staff Clarifies Registration Relief Available to Non-US Asset Managers

Morgan Lewis on

No-action relief confirms that non-US asset managers may rely on an exemption from CFTC registration when trading uncleared swaps in the United States for the accounts of their non-US clients, an issue that had been in doubt...more

Dechert LLP

CFTC Staff Issues No-Action Relief Helpful for Non-U.S. Commodity Pool Operators and Commodity Trading Advisors

Dechert LLP on

The U.S. Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) provided no-action relief on February 12, 2016 to commodity pool operators (CPOs) and commodity trading advisors...more

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