CPO | JD Supra Law News

NFA Amends CPO and CTA Quarterly Reporting Requirements

by Blake Brockway, Kevin M. Foley, Christian Hennion | Katten Muchin Rosenman LLP on 4/30/2013

On April 24, the National Futures Association (NFA) issued a notice to members regarding amendments to NFA Compliance Rule 2-46. The amended rule modifies the NFA’s quarterly pool reporting requirements and extends related...more

SEC and CFTC Issue Identity Theft Red Flags Rules Applicable to Financial Institutions and Creditors

by Timothy Blank, Nicholas DiLorenzo, Owen C.J. Foster, Christopher Harvey | Dechert LLP on 4/30/2013

The SEC and CFTC recently issued joint Identity Theft Red Flags Rules (the “Rules”), which are rules and guidelines requiring certain financial institutions worldwide to adopt comprehensive data security programs to detect...more

Corporate and Financial Weekly Digest - April 26, 2013

by Katten Muchin Rosenman LLP on 4/29/2013

In this issue: - NFA Amends CPO and CTA Quarterly Reporting Requirements - SDNY Imposes Second Highest Penalty Under Foreign Corrupt Practices Act - Grand Jury Indicts Swiss Lawyer and Banker in Tax...more

The SEC and CFTC Adopt Identity Theft Red Flag Rules

by Charley Lozada | Proskauer - Privacy & Data Security on 4/24/2013

The Securities and Exchange Commission (the “SEC”) and Commodity Futures Trading Commission (the “CFTC”) recently adopted rules requiring entities subject to their respective enforcement authorities to adopt and implement...more

The CFTC’s Further No-Action Relief for Operators of Securitization Vehicles that May Constitute Commodity Pools

by James Schwartz | Morrison & Foerster LLP on 4/11/2013

In a letter dated March 29, 2013 (the “March 29 Letter”), the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the “CFTC”), extended by three months, but subject...more

2013 Mutual Funds and Investment Management Conference

by Ropes & Gray LLP on 4/10/2013

In this presentation: - General Counsel’s Address - Keynote Address - General Session — It’s a Small World After All: How Non-U.S. Regulators Affect Your Business - General Session — Closer to...more

CFTC Staff Issues No-Action Letters

by Blake Brockway, Kevin M. Foley | Katten Muchin Rosenman LLP on 4/10/2013

The Commodity Futures Trading Commission staff recently released a series of letters relating to a variety of regulatory issues, including registration relief for certain entities and recordkeeping requirements for certain...more

CFTC No-Action Relief for Commodity Pools

by Orrick - Structured Finance Group on 4/9/2013

On April 2, the CFTC issued a time limited no-action letter that extended the deadline for compliance with reporting for commodity pool operators of securitization vehicles from March 31 until June 30....more

NFA Proposes Amendment Permitting Certain Loans by Commodity Pools to Related Entities

by Blake Brockway, Christian Hennion, Kenneth M. Rosenzweig | Katten Muchin Rosenman LLP on 3/13/2013

On March 4, the National Futures Association (NFA) issued a proposed rule change and interpretive notice that would allow commodity pools to provide certain loans to related commodity pool operators (CPOs) and other...more

401(k) Plans—Potential Commodity Pool Issues in the United States

by Susan M. Camillo, Andrew L. Oringer, M. Holland West | Dechert LLP on 2/28/2013

Under the rules of the Commodity Futures Trading Commission (“CFTC”), certain collective investment vehicles and other entities that, directly or indirectly, invest in “commodity interests” may be “commodity pools” whose...more

Family Office Relief from CPO Registration

by W. Scott McGinness Jr. | Miller & Martin PLLC on 2/26/2013

As noted in an earlier Client bulletin, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued a no-action letter dated November 29, 2012 enabling...more

NFA to Require CPOs to Identify Registered Investment Companies

by Kevin M. Foley, Kenneth M. Rosenzweig, Adam J. Spector | Katten Muchin Rosenman LLP on 2/6/2013

The National Futures Association (NFA) has notified its members that it will require each member of the NFA that is registered as a commodity pool operator (CPO) and operates one or more commodity pools that are also...more

Corporate and Financial Weekly Digest - February 1, 2013

by Katten Muchin Rosenman LLP on 2/4/2013

In this issue: - SEC Extends Expiration Date for Interim Final Rules Providing Exemptions for Security-Based Swaps - NFA Sets Implementation Deadline for Phase 1 of Customer Segregated Funds Reporting - CFTC to...more

Legal Alert: The CPO and CTA Regulatory Regimes: What Operators of and Advisers to Commodity Pools Should Expect in 2013

by Cheryl I. Aaron, James M. Cain, Doyle Campbell, Kalaundra Y. Carreathers, Warren N. Davis, Jacob Dweck, Daphne G. Frydman, Meghan R. Gruebner, Meltem F. Kodaman, Catherine M. Krupka, more +David T. McIndoe, Mark D. Sherrill, R. Michael Sweeney, Jr. | Sutherland Asbill & Brennan LLP on 1/18/2013

There were a number of significant changes to the regulatory regime for commodity pool operators (CPOs) and commodity trading advisors (CTAs) in 2012. As a result of these changes, various types of collective investment...more

Year-End Developments And Compliance Checklists

by Cole Beaubouef, Richard Bernstein, George Danenhauer, Marie DeFalco, David Goret, Peter Greene, Elaine Hughes, Allen Levithan, Matthew Magidson, Robert Minion, Scott H. Moss | Lowenstein Sandler LLP on 1/17/2013

Lowenstein Sandler’s Investment Management Group is pleased to provide you with (i) a summary of recent legislative and regulatory developments that impact the investment management community; and (ii) checklists of year-end...more

NFA Provides Bylaw 1101 Guidance to Commodity Pool Operators of Investment Companies

by Kathleen H. Moriarty, Peter J. Shea, Gregory E. Xethalis | Katten Muchin Rosenman LLP on 12/29/2012

Under amended Commodity Futures Trading Commission Regulation 4.5, registered investment advisers (RIAs) to registered investment companies engaging in more than minimal commodity trading activities will be required to...more

Exemption from NFA Assessment Fee for Proprietary Trading Firms that Register as CPOs

by James M. Brady, Kevin M. Foley, Kenneth M. Rosenzweig | Katten Muchin Rosenman LLP on 12/28/2012

The National Futures Association (NFA) has issued a notice temporarily exempting certain proprietary trading firms that may be required to be registered as commodity pool operators (CPOs) as of December 31, 2012, from the...more

CFTC's Division of Swap Dealer and Intermediary Oversight Issues No-Action Letter for Operators of Mortgage REITs

by White & Case LLP on 12/28/2012

On December 7, 2012, the Commodity Futures Trading Commission's (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter to mortgage real estate investment trusts (mREITs). The letter states...more

Corporate and Financial Weekly Digest - December 21, 2012

by Katten Muchin Rosenman LLP on 12/24/2012

In this issue: - Nallengara to Replace Cross as Corp. Fin. Chief - FINRA Rule Relating to Private Placements of Securities Effective December 3 - Additional Guidance on FINRA’s Suitability Rule - No-Action...more

Orrick's Financial Industry Week In Review - December 17, 2012

by Orrick, Herrington & Sutcliffe LLP on 12/20/2012

In This Issue: *Financial Industry Developments - CFTC No-Action Relief for Securitizations from Commodity Pool Operator Registration - CFTC No-Action Relief for Mortgage REIT Operators from Commodity Pool...more

Investment Management Legal + Regulatory Update -- December 2012

by Luke T. Bagley, Jay G. Baris, Steven J. Bleiberg, Thomas M. Devaney, Kelley A. Howes, Robert E. Putney, III, Isabelle Sajous | Morrison & Foerster LLP on 12/18/2012

In This Issue: Regulatory Updates - FSOC, FSB Turn Up Heat on SEC on Money Market Fund Reforms; SEC Staff: Beware of BDC Joint Transactions; SEC Reports 3,000 Whistles Blown in FYI 2012; Over 1500 Private Fund Advisers...more

CFTC Issues No-Action Letters

by Kevin M. Foley, Kenneth M. Rosenzweig | Katten Muchin Rosenman LLP on 12/18/2012

The Commodity Futures Trading Commission (CFTC) released a series of staff letters relating to various issues arising under rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act, including chief...more

Corporate and Financial Weekly Digest - December 14, 2012

by Katten Muchin Rosenman LLP on 12/17/2012

In this issue: - CFTC Issues No-Action Letters - SEC Division of Investment Management Lifts Actively-Managed ETF Derivatives Use Moratorium and Announces Two Rulemaking Initiatives - Antitrust “Tying” Claims...more

CFTC No-Action Relief for Mortgage REIT Operators from Commodity Pool Operator Registration

by Orrick - Structured Finance Group on 12/17/2012

On December 7, the CFTC issued a no-action letter to mortgage real estate investment trusts which provides that the Division of Swap Dealer and Intermediary Oversight will not recommend that the CFTC take enforcement action...more

CFTC Staff Provides Registration Relief for Family Offices

by Ropes & Gray LLP on 12/17/2012

On November 29, 2012, the Commodity Futures Trading Commission (“CFTC”) staff published relief for family offices that would otherwise be required to register with the CFTC as commodity pool operators (“CPOs”). This relief...more

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