News & Analysis as of September 22, 2024

Commodity Pool › Proposed Amendments

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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

Impact of Proposed Amendments to CFTC Regulation 4.7 on CPOs and CTAs

Morgan Lewis on 10/13/2023

The US Commodities Futures Trading Commission (CFTC) recently proposed new rules that, among other actions, update the definition of a “qualified eligible person,” add minimum disclosure requirements for certain pools and...more

NFA Provides Relief to Permit CTAs to Present Gross Past Performance to ECPs; CFTC Proposes Updates to Form CPO-PQR

Proskauer Rose LLP on 5/12/2020

In April, the National Futures Association (NFA) provided relief to permit commodity trading advisors (CTAs) who are also registered as investment advisers with the Securities and Exchange Commission (SEC) to provide...more

CFTC Proposes to Narrow its CPO-PQR to Conform to the NFA Form PQR and Add LEIs

Akin Gump Strauss Hauer & Feld LLP on 4/16/2020

On April 14, 2020, the Commodity Futures Trading Commission (CFTC) proposed, among other things, to narrow and revise the scope of information that it collects from commodity pool operators (CPOs) on its Form CPO-PQR to: ...more

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

CFTC Proposal to Amend CPO Reporting Rules

Broker-Dealer Compliance + Regulation on 8/19/2016

The Commodity Futures Trading Commission (“CFTC”) on August 5, 2016, issued a proposal to amend its rules governing commodity pool annual reports, which, if adopted, would permit commodity pool operators (“CPOs”) of a pool...more

NFA Proposes Amended Interpretive Notice Regarding Loans to CPOs by Commodity Pools

Katten Muchin Rosenman LLP on 12/24/2014

On December 12, National Futures Association (NFA) submitted to the Commodity Futures Trading Commission proposed amendments to the Interpretive Notice to NFA Compliance Rule 2-45 (Prohibition of Loans by Commodity Pools to...more

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