News & Analysis as of

Commodity Pool Operator Commodity Pool Commodity Trading Advisors (CTAs)

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 -
K&L Gates LLP

CFTC Proposes to Codify Relief for CPOs and CTAs

K&L Gates LLP on

Introduction - The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) is proposing amendments to its regulations governing commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) to codify...more

Orrick - Finance 20/20

CFTC Proposes to Streamline Regulations for Commodity Pool Operators and Commodity Trading Advisors

Orrick - Finance 20/20 on

On October 9, the Commodity Futures Trading Commission (“CFTC“) unanimously approved proposed rules as a part of its KISS initiative to simplify regulations for commodity pool operators (“CPOs“) and commodity trading advisors...more

Akin Gump Strauss Hauer & Feld LLP

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

• 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

Morgan Lewis

A Light Lift: CFTC Proposes to Codify Existing No-Action Relief and Other Relief Applicable to CPOs and CTAs

Morgan Lewis on

The US Commodity Futures Trading Commission has proposed a rule to streamline its regulation of commodity pool operators and commodity trading advisors, with most proposed amendments codifying, and in some cases broadening,...more

Eversheds Sutherland (US) LLP

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

Morgan Lewis

NFA Proposal Would Require CFTC-Registered Asset Managers to Report on Financial Condition

Morgan Lewis on

The National Futures Association’s (NFA’s) latest proposal would require registered commodity pool operators and commodity trading advisors to provide new information about their financial condition in quarterly reports to...more

Skadden, Arps, Slate, Meagher & Flom LLP

"NFA Requests Comments on Capital Requirements and Additional Customer Protection Measures for CPOs and CTAs"

The National Futures Association (NFA) recently issued a notice requesting comments on the advisability of subjecting registered commodity pool operators (CPOs) and registered commodity trading advisors (CTAs) to minimum...more

Katten Muchin Rosenman LLP

NFA Requests Comment on CPO/CTA Requirements

National Futures Association (NFA) has requested comments from its commodity pool operator (CPO) and commodity trading advisor (CTA) members on whether to adopt capital requirements to ensure that CPOs and CTAs have adequate...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review - November 12, 2013

CFTC Proposed Rule on Commodity Pools - On November 5, the CFTC issued a proposed rule that would require that all registered introducing brokers (IBs), commodity pool operators (CPOs) and commodity trading advisors...more

Orrick - Finance 20/20

CFTC Proposed Rule on Commodity Pools

Orrick - Finance 20/20 on

On November 5, the CFTC issued a proposed rule that would require that all registered introducing brokers (IBs), commodity pool operators (CPOs) and commodity trading advisors (CTAs) become and remain members of at least one...more

Katten Muchin Rosenman LLP

CFTC Adopts Final Harmonization Rules for Registered Investment Company Advisers Required to Register as CPOs Under Regulation...

On August 13, 2013, the Commodity Futures Trading Commission issued its final rules (“Final Rules”) applicable to registered investment companies now required to dually register as commodity pool operators (“Dually-Registered...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Amends Certain Record Retention and Document Distribution Requirements for All CPOs and CTAs

On August 13, 2013, the Commodity Futures Trading Commission (CFTC) adopted amendments to certain provisions of Part 4 of the CFTC regulations that are applicable to all commodity pool operators (CPOs) and commodity trading...more

Eversheds Sutherland (US) LLP

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

K&L Gates LLP

NFA Issues Guidance on Reaffirmation of CPO/CTA Exemptions

K&L Gates LLP on

Introduction - Earlier this year, the Commodity Futures Trading Commission (“CFTC”) promulgated amendments to its regulations governing commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) that now...more

Katten Muchin Rosenman LLP

NFA Issues Guidance on Annual Affirmation Requirement for CPO and CTA Exemptions

Commencing in 2012, each person or entity claiming an exemption from commodity pool operator (CPO) or commodity trading advisor (CTA) registration must annually affirm the applicable exemption within 60 days of the end of...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Delays Registration Deadline for Certain Commodity Pool Operators and Commodity Trading Advisors"

On October 12, 2012, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) issued “Temporary Registration No-Action Relief” (Temporary No-Action Relief) to commodity...more

Orrick - Finance 20/20

New CFTC Regulatory Regime for Private Fund Managers

Orrick - Finance 20/20 on

On April 24, the U.S. CFTC repealed the exemption from registration under the U.S. Commodity Exchange Act for private investment funds provided by CFTC Rule 4.13(a)(4). This Client Alert, written by Ed Eisert and Evelyn...more

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