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Commodity Pool Operator › Compliance

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 -
Vedder Price

2020 Annual Compliance Obligation Reminders

Vedder Price on

Investment advisers registered with the U.S. Securities and Exchange Commission (SEC) or with a state, as well as commodity pool operators and commodity trading advisors registered with the U.S. Commodity Futures Trading...more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

Dechert LLP on

The U.S. federal securities laws and the rules of U.S. self regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

Akin Gump Strauss Hauer & Feld LLP

2015-16 Compliance Developments & Calendar for Private Fund Advisers

Akin Gump Strauss Hauer & Feld LLP on

Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more

BakerHostetler

CA AG Requires Chief Privacy Officer and Privacy Compliance Program

BakerHostetler on

California’s Attorney General, Kamala Harris, has required Houzz, a home décor information and e-commerce website and mobile app publisher, to hire a chief privacy officer (CPO), conduct a company-wide privacy assessment, and...more

Goodwin

Financial Services Weekly News Roundup - September 2014

Goodwin on

In This Issue: The CFTC provided long-awaited exemptive relief for commodity pool operators that wish to offer their funds in private offerings using general solicitation under Rule 506(c) of the SEC’s Regulation D. ...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 36

Katten Muchin Rosenman LLP on

In this issue: - Bylaw of Delaware Corporation Providing for Exclusive Forum in North Carolina Upheld - FINRA Board to Consider Rule Proposals Regarding Private Trading Platforms - CBOE and C2 in...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Orrick, Herrington & Sutcliffe LLP on

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

Eversheds Sutherland (US) LLP

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

Eversheds Sutherland (US) LLP on

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

Katten Muchin Rosenman LLP

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

Katten Muchin Rosenman LLP on

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

Goodwin

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

Goodwin on

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

Eversheds Sutherland (US) LLP

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

Eversheds Sutherland (US) LLP on

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

Goodwin

NFA Seeks Comment on Possible Capital Requirements for CPOs and CTAs and Additional Customer Protection Measures

Goodwin on

The National Futures Association (“NFA”) issued Notice to Members I-14-03 seeking comment from its Member CPOs and CTAs as it considers (a) possible means of ensuring that each CPO or CTA has sufficient assets to operate as a...more

Eversheds Sutherland (US) LLP

CPO and CTA Annual Affirmation of Exemptions Due in March

Eversheds Sutherland (US) LLP on

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

Perkins Coie

Financial Services Bulletin: Action At The CFTC And CFPB

Perkins Coie on

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

Eversheds Sutherland (US) LLP

Legal Alert: CFTC Finalizes Harmonization Rules: Advisers to RICs Benefit From “Substituted Compliance” for Many Obligations

Eversheds Sutherland (US) LLP on

On August 13, 2013, the Commodity Futures Trading Commission (CFTC) adopted final rules to harmonize certain disclosure, reporting and recordkeeping obligations of commodity pool operators (CPOs) that are investment advisers...more

Morrison & Foerster LLP - JOBS Act

Advertising Restrictions Apply to Commodity Pools

Morrison & Foerster LLP - JOBS Act on

In prior posts, we have noted that the relaxation of the ban on general solicitation in no way relieves certain registered entities of their obligations to comply with regulations related to advertising or promotional...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

Skadden, Arps, Slate, Meagher & Flom LLP on

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

CFTC DSIO Issues FAQ on CPO and CTA Compliance

Orrick - Finance 20/20 on

On August 14, the CFTC Division of Swap Dealer and Intermediary Oversight issued a set of responses to frequently asked questions regarding compliance obligations for commodity pool operators and commodity trading advisers....more

K&L Gates LLP

CFTC Staff Responds to FAQs Regarding Rescission/Modification of CPO/CTA Registration Exemptions

K&L Gates LLP on

The Division of Swap Dealer and Intermediary Oversight (“DSIO”) of the Commodity Futures Trading Commission (“CFTC”) issued responses on August 14, 2012 to frequently asked questions (“FAQs”) submitted by several trade...more

Katten Muchin Rosenman LLP

CFTC Issues Guidance on Compliance Obligations for CPOs and CTAs

Katten Muchin Rosenman LLP on

On August 14, the Commodity Futures Trading Commission issued a set of responses to frequently asked questions (FAQs) related to the compliance obligations of commodity pool operators (CPOs) and commodity trading advisors....more

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