In This Presentation:

- OVERVIEW

- JOBS Act

- Rescinded Exemption for Pools with Highly Sophisticated Investors

- Rescinded Exemption for Pools with Highly Sophisticated Investors: Uncertain Futures

- Commodity Pool Definition

- CPO vs. CTA

- Definition of CPO

- Definition of CTA

- Regulation 4.13(a)(3) Conditions

- CTA Exemptions

- Exemption for Persons Who Operate Pools Composed Solely of “QEPs”

- Exemption for Persons Who Provide Advice to QEPs

- Registration as CPO and/or CTA

- APs & Principals: Definitions and Responsibilities

- CPO/CTA Compliance Obligations

- NFA By-Law 1101

- Due Diligence on Underlying Managers

- Other Compliance Obligations

- Transition and Compliance Issues

- Steps to Take Now