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
- 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
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
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
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
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