Commodity Pool 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 -
News & Analysis as of

Orrick's Derivatives in Review - July 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

Corporate and Financial Weekly Digest - Volume IX, Issue 23

In this issue: - SEC Chair Gives Speech on Equity Market Structure - New CFTC Commissioners Confirmed; Chairman Sworn In - CFTC Extends No-Action Relief for Certain Transaction-Level Requirements...more

CFTC Provides Streamlined No-Action Relief Filing Procedure to Certain Commodity Pool Operators Who Delegate Responsibilities to...

The Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (“CFTC” or the “Commission”) recently issued CFTC Letter No. 14-69 (May 12, 2014) (the “Letter”), which...more

CFTC Staff Announces Streamlined No-Action Relief Process for Certain CPOs

On May 12, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight announced a streamlined process that will allow a commodity pool operator (CPO) that has delegated investment management...more

Orrick's Financial Industry Week in Review

CFTC Announces New Approach for Considering Requests for Relief from Registration for Delegating Commodity Pool Operators - On May 12, CFTC Division of Swap Dealer and Intermediary Oversight announced a streamlined...more

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

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

Further Exclusions From Commodity Pool Regulation for Certain Securitization Vehicles; No-Action Relief for Certain Securitization...

I. Introduction - A. Issues Covered in the No-Action Letter - On December 7, 2012, the US Commodity Futures Trading Commission’s (“CFTC”) Division of Swap Dealer and Intermediary Oversight (the “Division”) issued a...more

CFTC No-Action Relief for Securitizations from Commodity Pool Operator Registration

On December 7, the CFTC provided guidance to securitization vehicles on whether they may be excluded from the definition of commodity pool....more

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

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 Issues Broad Securitization Industry Relief on Commodity Pool Regulation

On Friday, December 7, 2012, the U.S. Commodity Futures Trading Commission (CFTC), through its Division of Swap Dealer and Intermediary Oversight (Division), issued a letter which provides broad relief for certain segments of...more

"CFTC Staff Provides Funds-of-Funds With Temporary No-Action Relief From Commodity Pool Operator Registration"

On November 29, 2012, the Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) issued temporary no-action relief from commodity pool operator (CPO) registration to...more

CFTC Grants CPO Registration No-Action Relief to Business Development Companies

Under pending regulations of the U.S. Commodity Futures Trading Commission (CFTC)scheduled to take effect on January 1, 2013, business development companies (BDCs) and/or their sponsors or advisers (operators) would be...more

CFTC Issues No-Action Relief from Commodity Pool Operator Registration Requirements for Business Development Companies

On December 4, 2012, the Commodity Futures Trading Commission’s (CFTC’s) Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from commodity pool operator (CPO) registration requirements for...more

CFTC Staff No-Action Relief for Family Offices and Fund of Funds Operators

Claims for relief from CPO registration by qualifying family offices and fund of funds operators must be filed by December 31. On November 29, the Commodity Futures Trading Commission's (CFTC's) Division of Swap Dealer...more

"CFTC Staff Provides Family Offices With No-Action Relief From Commodity Pool Operator Registration"

On November 29, 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 family offices...more

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