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

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

CFTC Proposes Changes to Rule 4.7

On September 29, 2023, the CFTC approved a proposal to amend certain provisions of its regulations relating to commodity pools, specifically Rule 4.7. The proposal would be the first major change to Rule 4.7 in over 30...more

NFA Provides Relief to Permit CTAs to Present Gross Past Performance to ECPs; CFTC Proposes Updates to Form CPO-PQR

In April, the National Futures Association (NFA) provided relief to permit commodity trading advisors (CTAs) who are also registered as investment advisers with the Securities and Exchange Commission (SEC) to provide...more

CFTC Adopts Final Rules Clarifying CPO and CTA Exemptions for Family Offices, BDCs

On November 25, 2019, the Commodity Futures Trading Commission (CFTC) approved final rule amendments intended to simplify certain existing CFTC rules, codify certain previously granted no-action relief, and better coordinate...more

CFTC Adopts Additional Exemptions From Annual Privacy Notice Delivery Requirement

On April 19, 2019, the U.S. Commodity Futures Trading Commission (CFTC) approved a final rule revising the annual privacy notice delivery requirements applicable to CFTC registered commodity trading advisors, commodity pool...more

CFTC Proposes to Streamline CPO and CTA Regulations by Codifying Prior Relief

On October 9, 2018, the Commodity Futures Trading Commission (CFTC) proposed new rules in connection with the CFTC's Project KISS Initiative directed at simplifying Commodity Pool Operator (CPO) and Commodity Trading Advisor...more

CFTC Grants Relief to Family Offices from Registration as Commodity Trading Advisor

On November 5, 2014, the U.S. Commodity Futures Trading Commission (CFTC) issued a no-action letter granting relief from registration as a commodity trading advisor (CTA) to family offices that qualify for the family office...more

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