News & Analysis as of September 20, 2024

Commodity Pool › Registration Requirement

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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 +

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CFTC Adopts Bad Actor Disqualifications for CPO Exemptions

Akin Gump Strauss Hauer & Feld LLP on 6/12/2020

- A CPO will be prohibited from claiming an exemption from registration under CFTC Regulation 4.13 if it or any of its principals has in their backgrounds a statutory disqualification under the Commodity Exchange Act. - A...more

CFTC Proposes Relief for Non-US Commodity Pool Operators

Morgan Lewis on 6/9/2020

The US Commodity Futures Trading Commission has proposed amendments to CFTC Regulation 3.10(c)(3) to allow non-US commodity pool operators to claim an exemption from registration with respect to their offshore commodity pools...more

CFTC Proposes to Expand Availability of 3.10(c)(3) Registration Exemption for Non-U.S. Commodity Pool Operators

Akin Gump Strauss Hauer & Feld LLP on 6/2/2020

Commodity Futures Trading Commission (CFTC) Regulation 3.10(c)(3) currently provides that non-U.S. commodity pool operators (CPOs) are exempt from registration if they solely operate non-U.S. commodity pools offered 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 and NFA Year End Regulatory Updates

Akin Gump Strauss Hauer & Feld LLP on 12/27/2019

• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

CFTC Enforcement Priorities: Commodity Trading Advisory Services in Energy and Other Areas Under Scrutiny

Jones Day on 11/13/2019

The Situation: Recent enforcement actions and settlements by the U.S. Commodity Futures Trading Commission ("CFTC," or the "Commission") demonstrate that the Commission views registration violations as an enforcement...more

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 to Codify Existing Staff-Issued Relief from Registration and Other Compliance Requirements for CPOs and CTAs

Akin Gump Strauss Hauer & Feld LLP on 10/17/2018

• CPOs and CTAs of offshore commodity pools, family offices and business development companies would be exempt from registering with the CFTC. • Certain registered CPOs and CTAs would not be required to file Form CPO-PQR...more

Affirmations of CPO and CTA registration exemptions are due by March 1, 2018

Eversheds Sutherland (US) LLP on 2/14/2018

Persons claiming exemptions from registration as a commodity pool operator (CPO) or a commodity trading advisor (CTA) must affirm their exemptions by March 1, 2018. Pursuant to Commodity Futures Trading Commission (CFTC)...more

Treasury Report Addresses Regulatory Approaches Affecting Investment Companies and Their Advisers

Troutman Pepper on 10/31/2017

As required by President Trump’s Executive Order 13772, the U.S. Department of the Treasury issued a report, “A Financial System That Creates Economic Opportunities, Asset Management and Insurance,” addressing the regulatory...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 Provides Foreign Intermediary Registration Relief for Foreign Customers' Uncleared Swaps"

Skadden, Arps, Slate, Meagher & Flom LLP on 2/17/2016

The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (CFTC) has issued no-action relief from the requirement to register as an introducing broker (IB), commodity trading advisor...more

"CFTC Extends Registered Futures Association Membership Requirement to Introducing Brokers, Commodity Pool Operators and Commodity...

Skadden, Arps, Slate, Meagher & Flom LLP on 9/14/2015

The Commodity Futures Trading Commission (“CFTC”) unanimously approved a final rule (“Final Rule”) that formally extends the existing registered futures association (“RFA”) membership requirement to registered introducing...more

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Commodity Pool › Registration Requirement

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