News & Analysis as of

Commodity Pool Financial Institutions

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 -
Morgan Lewis

A Light Lift: CFTC Proposes to Codify Existing No-Action Relief and Other Relief Applicable to CPOs and CTAs

Morgan Lewis on

The US Commodity Futures Trading Commission has proposed a rule to streamline its regulation of commodity pool operators and commodity trading advisors, with most proposed amendments codifying, and in some cases broadening,...more

Morgan Lewis

NFA Proposal Would Require CFTC-Registered Asset Managers to Report on Financial Condition

Morgan Lewis on

The National Futures Association’s (NFA’s) latest proposal would require registered commodity pool operators and commodity trading advisors to provide new information about their financial condition in quarterly reports to...more

Morgan Lewis

FinCEN Requires Financial Institutions to Obtain Beneficial Ownership

Morgan Lewis on

FinCEN’s new CIP beneficial owner rules may hinder the ability of shell and nominee companies to directly access the US financial system without disclosing the natural persons who own 25% or more of the company. Pooled...more

Orrick - Finance 20/20

CFTC Approves Final Regulation Regarding Requirement to be a Member of a Registered Futures Association

Orrick - Finance 20/20 on

On September 10, the U.S. Commodity Futures Trading Commission Division issued a final rule requiring that all registered introducing brokers and commodity pool operators, and certain commodity trading advisors become and...more

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