Recent changes to the commodity pool regulations under the Commodity Exchange Act (the “CEA”) may subject certain securitization transactions and their managers to regulation by the Commodity Futures Trading Commission (the...more
In two interpretive letters issued on October 11, 2012 (collectively, the “Interpretive Letters”), the Division of Swap Dealers and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the...more