Commodity Pool Operator Swaps Dodd-Frank Wall Street Reform and Consumer Protection Act

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 -
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Financial Services Weekly News Roundup - September 2014

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

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

Corporate and Financial Weekly Digest - February 1, 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

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

CFTC Issues No-Action Letters

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

Treasury Department Issues Final Determination Exempting Foreign Exchange Swaps and Certain Foreign Exchange Forwards from the...

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

Pryor Cashman Attorneys Fry, Campoli and Dwyer Author Legal Update Discussing Elements of CFTC Regulations Applicable to Private...

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

The CFTC’s Interpretive Letters Regarding Securitizations, REITs and the Definition of “Commodity Pool”

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

CFTC Affords Relief and Guidance in Light of Final Swap Definition’s Effective Date

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

"CFTC Issues Interpretive Guidance for Securitizations and Defers Registration Deadline for Certain Persons"

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

CFTC Provides Temporary Relief Regarding Registration Deadlines for Certain CPOs and CTAs and the Treatment of Foreign Exchange...

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

CFTC Approves Conforming Amendments for CPO and CTA Regulations

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

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