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Commodity Trading Advisors (CTAs) Exemptions

Proskauer Rose LLP

Proskauer's Hedge Start: What Key Exemptions Apply to Hedge Funds?

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We have separately discussed the common exemptions from registration of a fund manager with the Securities and Exchange Commission (SEC) as an investment adviser and from registration with the Commodity Future Trading...more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more

WilmerHale

CFTC Proposes Amendments to CPO, CTA Regulations

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The Commodity Futures Trading Commission (CFTC or Commission) recently proposed amendments to CFTC Regulation 4.7 (the Proposed Rule) that would impact long-standing exemptions from certain compliance requirements for...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Expands Availability of 3.10(c)(3) Registration Exemption for Non-US Commodity Pool Operators and Commodity Trading Advisors

Commodity Futures Trading Commission (CFTC) Regulation 3.10(c)(3) currently provides an exemption from registration for non-U.S. commodity pool operators (CPOs) and commodity trading advisors (CTAs), if they solely operate...more

Cadwalader, Wickersham & Taft LLP

CFTC Codifies Registration and Reporting Relief for Commodity Pool Operators and Commodity Trading Advisors

The Commodity Futures Trading Commission (the “CFTC”) approved the publication of two releases (the “Final Rules”) on November 25, 2019, adopting final amendments to Part 4 of the CFTC Rules which codify and expand a number...more

Dechert LLP

CFTC Finalizes Regulation Amendments: Certain Registered and Exempt CPOs and CTAs Need to Take Action

Dechert LLP on

The Commodity Futures Trading Commission published in the Federal Register on December 10, 2019 several amendments to the regulatory framework applicable to certain commodity pool operators (CPOs) and commodity trading...more

Akin Gump Strauss Hauer & Feld LLP

CFTC and NFA Year End Regulatory Updates

• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

Eversheds Sutherland (US) LLP

BDCs must reclaim relief from CPO registration

On November 25, 2019, the Commodity Futures Trading Commission (CFTC) adopted several final regulations to codify existing exemptions from commodity pool operator (CPO) registration. Among them is an exemption that was issued...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Staff Extends Relief With Respect To Certain Position Limit Aggregation Requirements

Until August 12, 2022, CPOs and CTAs may continue to file position limit disaggregation notices upon request, rather than prospectively, and exempt CTAs may continue to rely upon the “independent account controller”...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Proposes to Simplify, Modernize Commodity Pool Operator and Commodity Trading Advisor Regulations

On October 18, 2018, the Commodity Futures Trading Commission (CFTC) published a proposal in the Federal Register (Proposed Rule) to amend several key compliance and registration regulations governing commodity pool operators...more

Dechert LLP

CFTC Proposes Amendments to Regulatory Framework for Certain CPOs and CTAs and New Exemption for CPOs of Non-U.S. Pools

Dechert LLP on

The Commodity Futures Trading Commission issued a Notice of Proposed Rulemaking on October 9, 2018 to amend certain aspects of the current regulatory framework applicable to commodity pool operators (CPOs) and commodity...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

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

Alston & Bird

Investment Management, Trading & Markets Advisory: Annual CPO or CTA Exemption or Exclusion Affirmations Due by February 29, 2016;...

Alston & Bird on

Any firm that is currently claiming certain exemptions or exclusions from registration with the Commodity Futures Trading Commission (CFTC) as a commodity pool operator (CPO) or commodity trading advisor (CTA) is required to...more

Morgan Lewis

Deadline Approaches for Annual CPO/CTA Exemption Filings

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Firms must affirm their exemption or exclusion from CPO or CTA registration on the National Futures Association’s Exemption Filing System by February 29....more

Katten Muchin Rosenman LLP

NFA Releases Guidance for Those Operating Under an Exemption or Exclusion From CPO or CTA Registration

On December 1, the National Futures Association (NFA) released guidance pertaining to the annual affirmation requirement for persons or entities that claim an exemption or exclusion from commodity pool operator (CPO)...more

Morgan Lewis

CFTC Staff Exempts Certain Commodity Trading Advisors from Form CTA-PR Reporting

Morgan Lewis on

The reporting relief applies to commodity trading advisors that do not “direct” trading of any client commodity interest trading accounts. On July 23, the CFTC’s Division of Swap Dealer and Intermediary Oversight issued...more

Katten Muchin Rosenman LLP

NFA Issues Guidance on Exempt and Excluded CPOs and CTAs

On December 3, National Futures Association (NFA) issued guidance reminding firms that are relying on certain exemptions or exclusions from registration as commodity pool operators (CPOs) or commodity trading advisors (CTAs)...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

Katten Muchin Rosenman LLP

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

Eversheds Sutherland (US) LLP

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

Goodwin

NFA Issues Guidance on Annual Affirmation Requirement for Entities Operating Under An Exemption or Exclusion from CPO or CTA...

Goodwin on

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

Katten Muchin Rosenman LLP

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

K&L Gates LLP

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

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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

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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