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... 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.
Cole-Frieman & Mallon partner/co-founder Bart Mallon Discusses CFTC Regulation 4.5, the Volcker Rule & Other Compliance Issues
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
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
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
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
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
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
On November 16, 2012, the United States Department of the Treasury (the “Treasury Department”) issued a final determination (the “Final Determination”) regarding the treatment of foreign exchange swaps and certain foreign...more
After December 31, 2012, the Commodity Futures Trading Commission (the “CFTC”) will no longer exempt managers of “pools” under Rule 4.13(a)(4) from registration as “commodity pool advisors” (“CPOs”). Consequently, managers of...more
In two interpretive letters issued on October 11, 2012 (collectively, the “Interpretive Letters”), the Division of Swap Dealers and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the...more
On October 12, 2012, the Commodity Futures Trading Commission’s (CFTC) and Securities and Exchange Commission’s (SEC) final rules to further define the term “swap” (among other terms) became effective. The effective date of...more
Securitization entities and most issuers of similar structured products (collectively, structured finance entities) historically have not been regulated as commodity pools by the Commodity Futures Trading Commission (CFTC)1...more
On October 11, 2012, the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (“CFTC”) granted temporary no-action relief to commodity pool operators (“CPOs”) and...more
Perhaps one of the most important questions since the Dodd-Frank Act is “What is a commodity pool”? Close behind is “Who is a commodity pool operator”? The CFTC has begun to shed light on these questions by issuance of...more
On September 5, the Commodity Futures Trading Commission published final conforming amendments to Part 4 of its regulations, which govern the operations and activities of CPOs and CTAs. These amendments reflect changes made...more
More video at MarketsWiki.tv Bart Mallon is a partner and co-founder of Cole-Frieman & Mallon, a San-Francisco-based law firm specializing in hedge fund and alternative investment legal services. His areas of...more
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