CFTC Proposes to Simplify, Modernize Commodity Pool Operator and Commodity Trading Advisor Regulations

by Skadden, Arps, Slate, Meagher & Flom LLP

Skadden, Arps, Slate, Meagher & Flom LLP

On October 18, 2018, the Commodity Futures Trading Commission (CFTC) published a proposal in the Federal Register (Proposed Rule)1 to amend several key compliance and registration regulations governing commodity pool operators (CPOs) and commodity trading advisors (CTAs). The overarching goal of the CFTC’s proposal is to simplify and modernize those regulations by codifying (and, in certain respects, expanding upon) relief in long-standing CFTC staff advisories and no-action letters.2

Registration Exemption for CPOs Operating in Multiple Jurisdictions

The CFTC proposes to amend CFTC Regulation 4.13 (which provides exemptions from CPO registration) so that a CPO would not have to register as a CPO with respect to any of its offshore pools for which the CPO solicits and/or accepts funds only from persons located outside the U.S. This registration exemption would be available on a pool-by-pool basis, meaning that the CPO could claim the exemption with respect to its offshore pools meeting the specified criteria for the new exemption while maintaining CPO registration with respect to other pools (e.g., offshore pools with U.S. participants).3

The proposed registration exemption is based on CFTC Staff Advisory 18-96, but the relief would be more extensive than Advisory 18-96, which does not offer an exemption from CPO registration but rather merely relief from certain compliance obligations. Further, the CFTC explained that the proposed registration exemption would be more flexible than the CPO registration exemption in CFTC Regulation 3.10(c)(3) because, whereas the proposed registration exemption can be claimed on a pool-by-pool basis, the 3.10(c)(3) exemption is available only to offshore CPOs that limit their CPO activities solely to offshore pools with offshore participants. According to the CFTC, in “providing CPO registration relief beyond that currently provided by [CFTC Regulation] 3.10(c)(3)(i) and by staff relief in Advisory 18-96,” the new registration exemption “would be beneficial and consistent with the [CFTC’s] past prioritization of agency resources for the regulation of intermediary activities affecting U.S. participants.”4 The existing timing and claims process for other CPO exemptions would apply to the proposed exemption, and all existing claimants under Advisory 18-96 could claim the proposed exemption.5

Relief From Record Location Requirement for Certain CPOs With Offshore Pools

The CFTC proposes to codify certain relief provided in Advisory 18-96 that would allow qualifying, registered onshore CPOs to maintain their offshore pool’s original books and records at the pool’s offshore location, rather than at the CPO’s main business office in the U.S. To qualify for this relief, a CPO would need to meet conditions that are based on the criteria for recordkeeping location relief set forth in Advisory 18-96.6

Prohibition on Claiming Certain CPO Registration Exemptions if Subject to Statutory Disqualification

The CFTC proposes to require any person claiming certain CPO registration exemptions under CFTC Regulation 4.13 to represent that neither the claimant nor any of its principals is subject to statutory disqualifications under Sections 8a(2) or 8a(3) of the Commodity Exchange Act.7 This proposed requirement is meant to address the CFTC’s concern that the current Part 4 regulations may present an “undue risk from a customer protection standpoint” by allowing a person that is statutorily disqualified from registering as a CPO to nonetheless claim a CPO registration exemption. Under the CFTC’s proposal, statutory disqualifications would not preclude claiming a CPO registration exemption where the disqualifications (1) were previously disclosed in a registration application that was granted, or (2) were disclosed more than 30 days prior to the claim of the CPO registration exemption.8

Inclusion of Non-US Persons as Type of Eligible Commodity Pool Participant in De Minimis Commodity Pools Under CFTC Regulation

The CFTC proposes to amend the CPO registration exemption under CFTC Regulation 4.13(a)(3) (often referred to as the de minimis exemption) to explicitly allow for non-U.S. persons, regardless of their financial sophistication, to be participants in the pools for which the de minimis exemption is claimed. This proposal would essentially codify the approach in CFTC Staff Letter 04-13, where CFTC staff confirmed that a CPO need not consider whether non-U.S. person participants meet the investor sophistication criteria of Rule 4.13(a)(3) in determining whether the CPO qualifies for the de minimis exemption.

CPO and CTA Registration Exemptions for Qualifying Family Offices

The CFTC proposes to adopt CPO and CTA registration exemptions that, in effect, codify two CFTC staff no-action letters relating to family offices. The proposed CPO registration exemption would be equivalent to the relief in CFTC Staff Letter 12-37,9 which permits “family offices” (as that term is defined in regulations promulgated by the Securities and Exchange Commission (SEC))10 to operate and manage assets of “family clients” (as that term is defined in SEC regulations)11 without having to register with the CFTC as a CPO.12 The proposed CTA registration exemption would be consistent with CFTC Staff Letter 14-143,1313 which permits family offices to provide their family clients with commodity trading advice, without CTA registration, provided that the family office does not hold itself out to the public as a CTA and restricts any commodity trading advice to the family office itself and/or family clients.14 Whereas the proposed CPO registration exemption would need to be claimed through an electronic notice filing, the proposed CTA registration exemption would be self-executing, i.e., not require a notice filing.15

Amendments Permitting General Solicitation by CPOs Pursuant to the JOBS Act

The CFTC is proposing targeted amendments to CFTC Regulations 4.7 and 4.13(a)(3) to ensure consistency with SEC regulations that have been implemented pursuant to the JOBS Act.16 In particular, the SEC adopted exemptions from securities registration requirements that allow for certain issuers and resellers of securities to engage in general marketing and solicitation.17 CFTC regulations come into play where such issuers and resellers of securities are also issuing shares in a commodity pool. Certain CFTC regulations prevent a CPO from claiming registration and/or regulatory compliance relief where the CPO is engaging in general marketing and solicitation. The CFTC is now seeking to harmonize its rules with those adopted by the SEC by eliminating the general marketing restriction in CFTC Regulations 4.7 and 4.13(a)(3) to the extent that the CPO claiming relief under those regulations is otherwise complying with the securities law exemptions. The CFTC’s proposed amendments in this regard would codify CFTC Staff Letter 14-116’s relief from the general marketing restriction in CFTC Regulations 4.7 and 4.13(a)(3).18

Exclusionary Relief for Business Development Companies

The CFTC proposes to amend Regulation 4.5 (which excludes certain otherwise regulated persons from the CPO definition) to exclude investment advisers of business development companies (BDCs) from the CPO definition. If adopted, this proposed amendment would effectively supersede no-action relief under CFTC Staff Letter 12-40, which provides CPO registration relief to the operators of BDCs provided that certain conditions are met. The CFTC explained that the reasons for proposing to exclude BDCs from the CPO definition are the same reasons that prompted CFTC staff to grant no-action relief for BDCs in Letter 12-40 — namely, BDCs are subject to oversight by the SEC that is comparable to the regulation of registered investment companies, and BDC’s use of commodity interests is primarily for bona fide hedging purposes.19

Relief From Filing Forms CPO-PQR and CTA-PR

The CFTC proposes to amend CFTC Regulation 4.27’s definition of a “reporting person,” which defines who is required to file a Form CPO-PQR for CPOs or a Form CTA-PR for CTAs. Currently, the “reporting person” definition includes CPOs and CTAs that are registered or required to be registered and therefore captures CPOs and CTAs that have elected to maintain an active registration with the CFTC even though they operate exempt pools or do not direct any client accounts. The CFTC’s proposed amendments would exclude from the “reporting person” definition CPOs that operate only pools for which they are otherwise excluded from the CPO definition or exempt from CPO registration, and CTAs that do not direct client accounts. These proposed amendments would be consistent with exemptive relief currently provided in CFTC Staff Letters 14-115 and 15-47. In addition, the CFTC proposes to exclude from the “reporting person” definition registered CTAs that only advise pools for which the CTA is also the CPO (whether registered as a CPO or exempt from CPO registration).20

Request for Comments

The CFTC raises specific questions for commenters on the proposed exemption to replace Advisory 18-96, the proposed family office exemptions, the proposal to amend Regulations 4.7 and 4.13(a)(3) to permit general solicitation in accordance with the JOBS Act, and the proposal to revise the “reporting person” definition relevant to CPO-PQR and CTA-PR filings.21 Comments on the proposal must be received on or before December 17, 2018.


1 See “Registration and Compliance Requirements for Commodity Pool Operators and Commodity Trading Advisors,” 83 Fed. Reg. 52,902 (Oct. 18, 2018).

2 Proposed Rule at 52,903-4.

3 Id. at 52,914, 52,926-7.

4 Id. at 52,921.

5 Id. at 52,914.

6 Id. at 52,906 and 52,927-8.

7 This proposed requirement would not apply to claiming the proposed CPO registration exemption for family offices, which is discussed infra.

8 Id. at 52,906 and 52,914.

9 See CFTC No-Action Letter 12-37.

10 SEC regulations define “family office” as a company (including its directors, partners, members, managers, trustees and employees acting within the scope of their position or employment) that: (1) has no clients other than family clients; (2) is wholly owned by family clients and is exclusively controlled (directly or indirectly) by one or more family members and/or family entities; and (3) does not hold itself out to the public as an investment adviser. 17 C.F.R. 275.202(a)(11)(G)–1(b).

11 SEC regulations define “family client” to mean (1) any family member; (2) any former family member; (3) any key employee; (4) certain former key employees; (5) any nonprofit organization, charitable foundation or charitable trust (including charitable lead trusts and charitable remainder trusts whose only current beneficiaries are other family clients and charitable or nonprofit organizations); (6) any estate of a family member, former family member or key employee, or certain former key employees that are covered in (4); (7) any irrevocable trust in which one or more other family clients are the only current beneficiaries; (8) any irrevocable trust funded exclusively by one or more other family clients in which other family clients and nonprofit organizations, charitable foundations, charitable trusts or other charitable organizations are the only current beneficiaries; (9) any revocable trust of which one or more other family clients are the sole grantor; (10) any trust of which: each trustee or other person authorized to make decisions with respect to the trust is a key employee; and each settlor or other person who has contributed assets to the trust is a key employee or the key employee’s current and/or former spouse or spousal equivalent who, at the time of contribution, holds a joint, community property or other similar shared ownership interest with the key employee; or (11) any company wholly owned (directly or indirectly) exclusively by, and operated for the sole benefit of, one or more other family clients; provided that if any such entity is a pooled investment vehicle, it is excepted from the definition of “investment company” under the Investment Company Act of 1940. 17 C.F.R. 275.202(a)(11)(G)-1(d)(4).

12 Proposed Rule at 52,908-9.

13 See CFTC No-Action Letter 14-143.

14 Proposed Rule at 52,909.

15 Id. at 52,915.

16 Id. at 52,915-16.

17 Proposed Rule at 52,909-10.

18 Id. at 52,911; see also CFTC No-Action Letter 14–116.

19 Proposed Rule at 52,916.

20 Id. at 52,916

21 Id. at 52,917.

Download pdf

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Skadden, Arps, Slate, Meagher & Flom LLP | Attorney Advertising

Written by:

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden, Arps, Slate, Meagher & Flom LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.