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SEC Proposes to Increase Form 13F Reporting Threshold

Proposed Amendments to Form 13F Would Increase the Reporting Threshold from $100 Million to $3.5 Billion, Among Other Changes On July 10, 2020, the U.S. Securities and Exchange Commission (SEC) issued a proposed rule (the...more

Updated: Covid-19 Compliance And Legal Considerations For Asset Managers

As the world responds to COVID-19, we have identified a wide variety of compliance and legal considerations for asset managers. We previously summarized a select list of these considerations on March 18, 2020. Given the...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

CFTC Swap Reporting No-Action Relief Granted; Other Dodd-Frank Deadlines Approaching

On April 9, 2013, the US Commodity Futures Trading Commission (the “CFTC”) granted last minute no-action relief from portions of the CFTC’s swap reporting rules. The relief delays certain compliance deadlines for many swap...more

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