Commodity Pool Operator Commodities Futures Trading Commission

Commodity Pool Operators are individuals who manage and secure capital for commodity pools. Most commodity pool operators are required to register as CPOs, unless they qualify for a registration exemption under... more +
Commodity Pool Operators are individuals who manage and secure capital for commodity pools. Most commodity pool operators are required to register as CPOs, unless they qualify for a registration exemption under the Commodity Futures Trading Commission regulations.  less -
News & Analysis as of

U.S. House Votes to Reauthorize the CFTC and Exclude Most RICs from CPO and CTA Requirements

The U.S. House of Representatives on June 24, 2014, passed a version of the CFTC reauthorization bill, H.R. 4413, that would exclude investment advisers to registered investment companies (RICs) from the definitions of...more

NFA Issues Revised Forms CPO-PQR and CTA-PR

On June 5, the National Futures Association (NFA) announced the issuance of revised Forms CPO-PQR and CTA-PR. The NFA is the self-regulatory organization to which the Commodity Futures Trading Commission (CFTC) has delegated...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 Implements Standard Approach for CPO Delegated Investment Management Authority

On May 12, the Division of Swap Dealer and Intermediary Oversight of the CFTC announced the implementation of a standardized, streamlined approach for processing requests for relief where a CPO that has delegated investment...more

Orrick's Financial Industry Week in Review

EU Commission Sends Statement of Objections to Three Banks in Cartel Investigation - On May 20, the European Commission announced that it has sent a statement of objections to Credit Agricole, HSBC and JP Morgan for...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

CFTC Announces Streamlined Approach for Seeking Relief from Registration for Delegating Commodity Pool Operators

The CFTC’s Division of Swap Dealer and Intermediary Oversight (the “Division”) announced a streamlined approach for requesting relief from the commodity pool operator (“CPO”) registration requirement for a CPO that delegates...more

CFTC Announces Streamlined CPO Delegation Process

On May 12, 2014, the Commodity Futures Trading Commission (CFTC) issued a no-action relief letter adopting a streamlined approach for commodity pool operator (CPO) delegation. The letter clarifies the conditions under which a...more

Legal Alert: CFTC Adopts Streamlined Approach for Delegation of CPO Registration

On May 12, 2014, the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued a staff letter (the Staff Letter) that provides a streamlined approach for commodity pool...more

Corporate and Financial Weekly Digest - Volume IX, Issue 20

In this issue: - Delaware Supreme Court Upholds Fee-Shifting Bylaw - FINRA Proposes Changes to FINRA Rules 7410 and 2121 - CFTC Staff Announces Streamlined No-Action Relief Process for Certain...more

The Financial Report - Volume 3, No. 10 • May 2014 (Global)

News from the Americas - High-speed trading. Bloomberg discussed US Senate Agriculture Committee hearings on high-speed trading. Former CFTC economist Andrei Kirilenko said that new books and records requirements and...more

CFTC Staff Announces Streamlined Process for CPO Delegation

On March 12, 2014, the Commodity Futures Trading Commission (CFTC) staff issued the long-awaited guidance letter relating to the delegation of commodity pool operator (CPO) functions from persons that might otherwise be...more

CFTC Staff Updates Requirements for the Delegation of CPO Functions

On May 12, 2014, the Commodity Futures Trading Commission (“CFTC”) staff issued Letter 14-69 (the “Letter”), which requires that specific no-action relief be obtained when a commodity pool operator (“CPO”) of a fund delegates...more

"CFTC Staff Issues Long-Awaited CPO Delegation Relief"

On May 12, 2014, the Division of Swap Dealer and Intermediary Oversight (Division) of the Commodity Futures Trading Commission (CFTC) released its long-awaited commodity pool operator (CPO) delegation no-action letter...more

CFTC Issues Advisory on Compliance with Gramm-Leach-Bliley Act Security Safeguards

On February 26, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission issued Advisory 14-21 to provide futures commission merchants, commodity trading advisors, commodity...more

NFA Provides Further Guidance on Bylaw 1101 Obligations of Members Who Do Business with CPOs/CTAs Relying on an Exemption or...

The National Futures Association (the “NFA”) issued Notice I-14-06 providing guidance to its members regarding their Bylaw 1101 obligation to determine the CFTC registration and NFA membership status of persons with whom they...more

NFA Requests Comments on Need for CPO/CTA Capital Requirements

Should the National Futures Association (NFA) impose capital requirements on commodity pool operators (CPOs) and commodity trading advisors (CTAs)? On January 23, 2014, the NFA published a Notice to members seeking public...more

Commodity Pool Operators and Commodity Trading Advisors: Are Enhanced Customer Protections on the Horizon?

On January 23, 2014, the National Futures Association (NFA) issued a Request for Comments from commodity pool operators (CPOs) and commodity trading advisors (CTAs) as to whether the NFA should adopt rules to: (1) ensure that...more

CPO and CTA Annual Affirmation of Exemptions Due in March

Pursuant to Commodity Futures Trading Commission (CFTC) regulations, persons claiming an exemption or exclusion from registration as a commodity pool operator (CPO) or a commodity trading advisor (CTA), under CFTC Regulations...more

NFA Issues Guidance on Annual Affirmation Requirement for Entities Operating Under An Exemption or Exclusion from CPO or CTA...

The National Futures Association (the “NFA”) has issued guidance reminding market participants of CFTC regulations that require any person claiming an exemption or exclusion under CFTC Regulation 4.5, 4.13(a)(1), 4.13 (a)(2),...more

Year-End CFTC Reporting Requirements for Fund Advisers

The National Futures Association (NFA) reminded fund advisers claiming an exemption from registering as a commodity pool operator (CPO) that they must confirm by March 3, 2014 that will continue to rely on the exemption....more

Corporate and Financial Weekly Digest - Volume VIII, Issue 46

In this issue: - SEC Division of Corporation Finance Issues 14 New C&DIs Relating to “Bad Actor” Rules - NASDAQ Proposes Change to Listing Rules Regarding Compensation Committee Independence - FINRA...more

Financial Services Bulletin: Action At The CFTC And CFPB

CFTC Proposes Registered Futures Association Membership Rules - On Friday, November 8, 2013, the Commodity Futures Trading Commission (the "CFTC") proposed amending its regulations to require that all persons...more

The Financial Report - Volume 2, No. 21 • November 2013 (Global)

Discussion and Analysis - This week, the Oxford Dictionaries chose “selfie” as the word of the year. It beat out a number of other relatively new Internet and social-media related terms, including “bitcoin.” In...more

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