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CFTC Acting Chair Caroline D. Pham Announces CFTC’s 30-Day Enforcement Sprint

On February 25, 2025, the U.S. Commodity Futures Trading Commission (CFTC) released an enforcement advisory regarding the impact of self-reporting, cooperation and remediation in enforcement cases (the “Enforcement...more

CFTC’S Year-End AI “Placeholder” Guidance

On December 5, 2024, the Staff of every market-facing division of the U.S. Commodity Futures Trading Commission (CFTC) issued a joint “Staff Advisory” on the use of artificial intelligence in CFTC-regulated markets and...more

SEC Staff Extends ‘Net’ Performance Presentation Requirement to Case Studies

As a general principle, the Marketing Rule requires registered investment advisers to include net performance alongside any presentation of gross performance. Market practice on whether or how this principle applies to case...more

2022 Compliance Developments and Calendar for Private Fund Advisers

Compliance Reminders for 2022 - Registered investment advisers to private funds clients are required to make filings with the Securities and Exchange Commission (SEC) each year and deliver certain information to their...more

New Outsourced Compliance Guidance – Implications for CFTC-Registered Private Fund Managers

Key Point - As of September 30, 2021, private fund managers registered with the CFTC as CPOs or CTAs will be required, under new NFA guidance, to supervise certain third-parties performing regulatory functions....more

CFTC Proposes Electronic Trading Principles in Lieu of Reg AT

- The Commodity Futures Trading Commission (CFTC) formally withdrew its highly controversial “Regulation Automated Trading” (Reg AT). - In its place, the CFTC proposed principles-based rules applicable to designated...more

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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