News & Analysis as of September 22, 2024

CPOs

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

Skadden, Arps, Slate, Meagher & Flom LLP on 11/14/2018

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

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

Morgan Lewis on 8/4/2016

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

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

Morgan Lewis on 2/22/2016

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

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

Dechert LLP on 2/19/2016

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

CFTC Announces Self-Executing No-Action Relief for Delegating CPOs

Proskauer Rose LLP on 10/21/2014

On October 15, 2014, the Commodity Futures Trading Commission (CFTC) issued a no-action relief letter granting self-executing registration no-action relief to qualifying commodity pool operators (CPOs) that delegate their CPO...more

Registration Relief for Some Delegating CPOs

Carlton Fields on 10/2/2014

In May, the Commodity Futures Trading Commission (CFTC) staff announced a streamlined process that allows persons seeking no-action relief to avoid registering as commodity pool operators (CPOs). They must, however, designate...more

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