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Cryptocurrencies: A Big Week for U.S. Regulatory Attention

SEC/CFTC Statements - In an op-ed published in the Wall Street Journal on January 24, 2018, Jay Clayton, the Chair of the US Securities and Exchange Commission (SEC), and J. Christopher Giancarlo, the Chair of the US...more

CFTC Staff Issues Revised No-Action Relief from CPO Registration for Certain Delegating CPOs

On October 15, 2014, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the US Commodity Futures Trading Commission (“CFTC”) issued a no-action letter (“Letter 14-126”)1 providing conditional relief from...more

CFTC Staff Issues Exemptive Letter Facilitating Broader Marketing of Certain Commodity Pools

On September 9, 2014, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the US Commodity Futures Trading Commission (“CFTC”) issued an exemptive letter (“Letter”) harmonizing certain CFTC restrictions on...more

CFTC Adopts Harmonization Rules for CPOs of Registered Investment Companies

The US Commodity Futures Trading Commission (“CFTC”) has adopted widely anticipated rules regarding the application of its commodity pool operator (“CPO”) regulatory regime to CPOs of registered investment companies...more

Life After CPO Registration: Select CFTC and NFA Compliance Obligations that Lie Ahead

Over the last few months, an exceptional number of investment management firms have either registered or prepared to register with the Commodity Futures Trading Commission (“CFTC”) as “commodity pool operators” (“CPOs”). Many...more

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