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Exemptions National Futures Association

Eversheds Sutherland (US) LLP

Swap APs exempt from Branch Office Manager Series 30 Examination requirement effective January 3, 2022

On Monday, November 27, 2021, the National Futures Association (NFA) submitted to the CFTC proposed amendments to NFA Compliance Rule 2-7 to exclude associated persons (APs), designated as “swap” APs, from the Branch Office...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Adopts Bad Actor Disqualifications for CPO Exemptions

- A CPO will be prohibited from claiming an exemption from registration under CFTC Regulation 4.13 if it or any of its principals has in their backgrounds a statutory disqualification under the Commodity Exchange Act. - A...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

Foley Hoag LLP

CFTC 4.13(a)(3) Annual Affirmations Due February 29

Foley Hoag LLP on

As a reminder, fund managers relying on the exemption from registration with the US Commodity Futures Trading Commission (the “CFTC”) set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...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

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