Commodity Trading Advisors

News & Analysis as of

CFTC Proposes to Fix Problematic Oral Communication Recordkeeping Rule

The U.S. Commodity Futures Trading Commission (CFTC) held an open meeting in early November 2014 at which it discussed and proposed, among other agenda items, amendments to rules regarding recordkeeping related to commodity...more

CFTC Proposes Amendments to Recordkeeping Rules

Proposed changes would provide permanent relief from compliance with certain recordkeeping requirements and narrow the types of records that must be identifiable by transaction. The December 2012 amendments to...more

NFA Issues Notice Regarding CPO and CTA Reports and Filing Requirements

On October 1, National Futures Association issued Notice to Members I-14-26 informing commodity pool operators (CPOs) of changes to Form PQR and to remind member CPOs and commodity trading advisors (CTAs) to file required...more

Corporate and Financial Weekly Digest - Volume IX, Issue 39

In this issse: - ISS Publishes Results of Annual Global Voting Policy Survey - FINRA Requests Comment on a Rule Proposal to Implement the Comprehensive Automated Risk Data System - NFA Issues Notice...more

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

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 Issues Notice to Members Regarding Member Obligations Under NFA Bylaw 1101 and Compliance Rule 2-36(d)

Under Commodity Futures Trading Commission regulations, any person claiming an exemption or exclusion from commodity pool operator (CPO) or commodity trading advisor (CTA) registration pursuant to CFTC Regulations 4.5,...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

"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

NFA Seeks Comment on Capital Requirements for CPOs and CTAs

National Futures Association (NFA), the industry-funded self-regulatory for the futures industry, issued a Notice to Members (Notice) on January 23, 2014, requesting comment on the concept of imposing a capital requirement on...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

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

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

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

Private Funds In Focus - Winter 2014

Year End Update – Compliance: Certain Upcoming U.S. Regulatory Deadlines - The list below briefly summarizes various regulatory obligations and filing deadlines for private fund managers under U.S. rules....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

CFTC Extends Relief from Oral Communication Recording Requirement

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight issued No-Action Letter No. 13-77, which extends the oral communications recording compliance...more

CFTC Issues Advisory Concerning Commodity Trading Advisors and Swaps

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued Advisory No. 13-79 to provide guidance to commodity trading advisors (CTAs) on new obligations relating to swaps...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

NFA Issues Guidance on Affirmation Process for CPO and CTA Exemptions and Exclusions

The National Futures Association (NFA) issued guidance on the annual affirmation requirement for persons operating under an exemption or exclusion from commodity pool operator (CPO) or commodity trading advisor (CTA)...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

CFTC Proposes Rule to Require All Registered Introducing Brokers, Commodity Pool Operators, and Commodity Trading Advisors to be...

The CFTC has proposed a rule that would require all registered introducing brokers (“IBs”), commodity pool operators (“CPOs”), and commodity trading advisors (“CTAs”) to be members of a registered futures association (“RFA”)....more

CFTC Proposes Rules to Require that IBs, CPOs and CTAs Become Members of a Registered Futures Association

The Commodity Futures Trading Commission has proposed rules requiring that all registered introducing brokers (IBs), commodity pool operators (CPOs) and commodity trading advisors (CTAs) become members of at least one...more

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

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 (CTAs) become and remain members of at least one...more

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