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National Futures Association Commodities Futures Trading Commission

Alston & Bird

CFTC Commissioner Warns That CCOs May Face Personal Liability

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Our Investment Funds Group reviews the implications of a Commodity Futures Trading Commission (CFTC) policy targeting chief compliance officers (CCOs) as individuals if their companies’ compliance programs fail....more

Lowenstein Sandler LLP

Material Investment Management Developments and Template Annual Compliance Checklists for Registered Investment Advisers, Exempt...

Summaries of recent legislative and regulatory developments with respect to: •SEC’s 2022 Examination Priorities • Proposed Amendments to Form PF Requirements- •Proposed New Rules Applicable to Private Fund Advisers and...more

Morrison & Foerster LLP

Commodities Futures Trading Commission and National Futures Association Announce Enforcement Trends and Priorities

The Commodities Futures Trading Commission (CFTC) and the National Futures Association (NFA) have outlined a broad enforcement agenda that aims to address recent commodities marketplace trends....more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on FINRA's 2021 Budget and Industry Spotlight and Dues Increases for NFA...

BROKER-DEALER - FINRA Publishes 2021 Industry Spotlight - On May 25, the Financial Industry Regulatory Authority (FINRA) published the 2021 FINRA Industry Spotlight (Industry Spotlight), which is FINRA’s annual...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on the Latest Guidance From the SEC on SPACs and a FINRA Reminder for...

SEC/CORPORATE - SEC Statements Regarding SPACs Address Warrants and Projections - Following the increase in the number of special purpose acquisition companies (SPACs) and the related business combinations between SPACs...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on CFTC Guidance for Futures Commission Merchants on Risk Assessments and...

BROKER-DEALER - 2021 Advisory Committee Overview and Engagement Notice - On March 26, the Financial Industry Regulatory Authority (FINRA) published a notice encouraging employees of member firms and other interested...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on ESG and Climate-Risk Disclosure Initiatives from the SEC, CFTC European...

SEC/CORPORATE - Acting SEC Chair Lee Provides Public Statement Welcoming Public Comment on Climate Change Disclosures - On March 15, Acting Securities and Exchange Commission Chair Allison Herren Lee made a public...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on FINRA's Regulatory Notice on Policies and Procedures for Low-Priced...

SEC/CORPORATE - SEC Staff Releases Sample Comment Letter on Securities Offerings During Periods of Market and Price Volatility - On February 8, the staff of the SEC’s Division of Corporation Finance (the Staff)...more

Orrick - Finance 20/20

CFTC Approves NFA’s Swap Dealer Capital Model Review Program

Orrick - Finance 20/20 on

On January 13, the Commodity Futures Trading Commission’s (CFTC) Market Participation Division determined that the National Futures Association’s (NFA) swap dealer capital model requirements and review program is comparable...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on SEC proposes amendments to Rule 144, Elad Roisman named Acting Chairman...

SEC/CORPORATE - SEC Proposes Rule 144 Tacking Amendments - On December 22, 2020, the Securities and Exchange Commission voted to propose amendments to Rule 144 under the Securities Act of 1933 (the Securities Act)...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on SEC Announces FinHub as Stand-Alone Office, CFTC Approves Final Rule...

BROKER-DEALER - SEC Adopts Rules to Modernize Infrastructure for NMS Market Data - On December 9, the Securities and Exchange Commission adopted final rules that aim to modernize the infrastructure related to the...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on Additional LIBOR Replacement Materials from the ARRC, Amendments to...

BROKER-DEALER - FINRA Announces Updates to Interpretations of Margin Rule Regarding Control and Restricted Securities and Consolidation of Accounts - On July 2, the Financial Industry Regulatory Authority (FINRA) issued...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on New Disclosure Guidance From the SEC, Changes to Initial Margin Rules...

SEC/CORPORATE - SEC Division of Corporation Finance Issues Additional Disclosure Guidance Related to COVID-19 Pandemic - On June 23, the Division of Corporation Finance (the Division) of the Securities and Exchange...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on CBOE Exchange to Temporarily Extend Filing Deadline for Certain...

BROKER-DEALER - CBOE Exchange Proposes to Temporarily Extend the Filing Deadline for Certain Supervision-Related Reports - On June 1, Cboe Exchange, Inc. (Cboe) filed with the Securities and Exchange Commission a...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on Breaking News From the CFTC on Non-US CPO Registration Exemption and a...

BROKER-DEALER - SEC Amends CAT NMS Plan - On May 15, the Securities and Exchange Commission adopted amendments to the national market system plan governing the consolidated audit trail (the CAT NMS Plan). The Financial...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on Continued Changes by FINRA, CFTC and the NFA in Response to COVID-19...

BROKER-DEALER - FINRA Proposes Rule Change to Temporarily Amend Certain Timing, Method of Service and Other Procedural Requirements in FINRA Rules - On May 8, the Financial Industry Regulatory Authority (FINRA) filed...more

Dechert LLP

CFTC Proposes Changes to Form CPO-PQR

Dechert LLP on

The Commodity Futures Trading Commission published on April 14, 2020, a proposal to amend certain compliance requirements for commodity pool operators under CFTC Rule 4.27 and CFTC Form CPO-PQR, as codified at Appendix A to...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Proposes to Narrow its CPO-PQR to Conform to the NFA Form PQR and Add LEIs

On April 14, 2020, the Commodity Futures Trading Commission (CFTC) proposed, among other things, to narrow and revise the scope of information that it collects from commodity pool operators (CPOs) on its Form CPO-PQR to: ...more

Morgan Lewis

COVID-19: US Regulatory Relief and Related Effects on Markets and Participants

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The US Securities and Exchange Commission, Financial Industry Regulatory Authority, Commodity Futures Trading Commission, and National Futures Association have each announced temporary regulatory relief for market...more

Morgan Lewis

CFTC and NFA Issue Additional COVID-19 Regulatory Relief

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The Commodity Futures Trading Commission and the National Futures Association in recent weeks have issued relief in response to the challenges that many market participants face in light of the coronavirus (COVID-19)...more

Dechert LLP

CFTC and NFA Issue Relief for Registered CPOs and CTAs in Response to Disruptions Caused by COVID-19 Coronavirus Pandemic

Dechert LLP on

The Commodity Futures Trading Commission issued industry-wide no-action relief for registered commodity pool operators on March 20, 2020, to permit those CPOs additional time to make certain regulatory filings and issue...more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - February 2020

Dechert LLP on

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

Dechert LLP

SEC Proposes Rule Changes Applicable to BDCs’ Use of Derivatives and Other Transactions

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The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a rule proposal related to the use of derivatives and certain other transactions by companies that have elected to be...more

Dechert LLP

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

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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

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