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Commodity Pool › Commodity Trading Advisors (CTAs)

A Commodity Pool is an investment structure or enterprise where funds from a number of participants are combined into a single entity for the purpose of trading futures contracts, options on contracts, retail... more +
A Commodity Pool is an investment structure or enterprise where funds from a number of participants are combined into a single entity for the purpose of trading futures contracts, options on contracts, retail off-exchange forex contracts or swaps, or to invest in another commodity pool.   less -
Lowenstein Sandler LLP

CFTC Finalizes Long-Awaited Update to Rule 4.7

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On September 12, the Commodity Futures Trading Commission (CFTC or Commission) published a final rule, adopting amendments to CFTC Rule 4.7, which provides exemptive relief from certain compliance obligations to registered...more

Alston & Bird

CFTC Amends Regulation 4.7, Increasing Dollar Threshold for QEP Qualification and Codifying Monthly Reporting Option for Funds of...

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Our Investment Funds Group examines how the Commodity Futures Trading Commission (CFTC) has amended Regulation 4.7 to increase investor suitability standards and provide additional flexibility for funds-of-funds reporting....more

Akin Gump Strauss Hauer & Feld LLP

CFTC Finalizes Amendments to Rule 4.7

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On September 12, 2024, the Commodity Futures Trading Commission (CFTC) finalized the first major changes to CFTC Regulation 4.7 (Rule 4.7) in over 30 years. Among other technical revisions, the amendments to Rule 4.7,...more

Dechert LLP

Registered CPOs and CTAs Must Take Action with NFA by October 2024

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Pursuant to new National Futures Association (NFA) Compliance Rule 2-52, Interpretive Notice 9082 and amendments to NFA Bylaw 301, for NFA membership filings, membership renewals and material updates made after October 15,...more

Proskauer Rose LLP

Proskauer's Hedge Start: What Key Exemptions Apply to Hedge Funds?

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We have separately discussed the common exemptions from registration of a fund manager with the Securities and Exchange Commission (SEC) as an investment adviser and from registration with the Commodity Future Trading...more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more

Cadwalader, Wickersham & Taft LLP

CFTC Issues Proposed Rule to Modify Regulation 4.7 Exemptions

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On October 2, 2023, the Commodity Futures Trading Commission (the “Commission” or “CFTC”) published a notice of proposed rulemaking (the “Proposed Rule”) to amend CFTC Regulation 4.7, which provides exemptions to registered...more

Morgan Lewis

Impact of Proposed Amendments to CFTC Regulation 4.7 on CPOs and CTAs

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The US Commodities Futures Trading Commission (CFTC) recently proposed new rules that, among other actions, update the definition of a “qualified eligible person,” add minimum disclosure requirements for certain pools and...more

WilmerHale

CFTC Proposes Amendments to CPO, CTA Regulations

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The Commodity Futures Trading Commission (CFTC or Commission) recently proposed amendments to CFTC Regulation 4.7 (the Proposed Rule) that would impact long-standing exemptions from certain compliance requirements for...more

Lowenstein Sandler LLP

Material Investment Management Developments and Template Annual Compliance Checklists for Registered Investment Advisers, Exempt...

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Lowenstein Sandler’s Investment Management Group is pleased to provide you with the summaries and checklists described below. Summaries of recent legal developments with respect to: •SEC’s 2023 Examination Priorities- ...more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

Foley Hoag LLP on

INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

Foley Hoag LLP on

INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level, are required to review their compliance policies and...more

Akin Gump Strauss Hauer & Feld LLP

2022 Compliance Developments and Calendar for Private Fund Advisers

Akin Gump Strauss Hauer & Feld LLP on

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

Akin Gump Strauss Hauer & Feld LLP

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

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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

Dechert LLP

NFA Institutes New Operational Requirements for Members; Registered CPOs and CTAs Need to Take Action in Q3 and Q4 2021

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The National Futures Association has adopted two new operational requirements that will affect (among others) registered commodity pool operators and commodity trading advisors. Under new NFA Compliance Rule 2-50, as of...more

Morgan Lewis

National Futures Association Proposes New Reporting Requirements for Commodity Pool Operators

Morgan Lewis on

The National Futures Association (NFA) has proposed a new rule that would require registered commodity pool operators (CPOs) that are members of the NFA (CPO Members) to report to the NFA by 5:00 pm Central Time the next...more

Foley Hoag LLP

Important Dates and Reminders For Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

Foley Hoag LLP on

INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level, are required to review their compliance policies and...more

Dechert LLP

CFTC Broadens Available Exemption for Non-U.S. CPOs

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The Commodity Futures Trading Commission, on December 7, 2020, published in the Federal Register significant amendments to CFTC Regulation 3.10(c) (Amendments), making the regulation a more broadly available registration...more

Kilpatrick

New CFTC Rules Taking Effect: Investment Advisers to Registered Investment Companies (RICs) Must Claim the Rule 4.5 CPO Exclusion...

Kilpatrick on

On December 10, 2019, the Commodity and Futures Trading Commission (“CFTC”) published amendments to the rules governing Commodity Pool Operators (“CPOs”) and Commodity Trading Advisers (“CTAs”) (the “New Rules"). Among other...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Expands Availability of 3.10(c)(3) Registration Exemption for Non-US Commodity Pool Operators and Commodity Trading Advisors

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Commodity Futures Trading Commission (CFTC) Regulation 3.10(c)(3) currently provides an exemption from registration for non-U.S. commodity pool operators (CPOs) and commodity trading advisors (CTAs), if they solely operate...more

Dechert LLP

Registered and Exempt Market Participants May Need to Plan Ahead to Take Action Early in 2021 to Address CFTC and NFA Rule and...

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During the course of 2019 and 2020, the Commodity Futures Trading Commission and the National Futures Association (NFA, the self-regulatory organization for the U.S. futures and swaps industry) have been hard at work amending...more

Proskauer Rose LLP

NFA Provides Relief to Permit CTAs to Present Gross Past Performance to ECPs; CFTC Proposes Updates to Form CPO-PQR

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In April, the National Futures Association (NFA) provided relief to permit commodity trading advisors (CTAs) who are also registered as investment advisers with the Securities and Exchange Commission (SEC) to provide...more

Vedder Price

NFA Issues COVID-19 Alert on Business Continuity Plans, Relief for Branch Office Requirements and Reminder on Upcoming Deadline...

Vedder Price on

On March 4, 2020, the National Futures Association (the “NFA”) issued a notice to its members addressing concerns surrounding the coronavirus (COVID-19). With the coronavirus’s potential to interfere with members’ regulatory...more

A&O Shearman

COVID-19: Compliance and Legal Considerations for Asset Managers

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As the world responds to COVID-19, we have identified a number of compliance and legal considerations for asset managers. We summarize a select list of these in our note below....more

Cadwalader, Wickersham & Taft LLP

CFTC Codifies Registration and Reporting Relief for Commodity Pool Operators and Commodity Trading Advisors

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The Commodity Futures Trading Commission (the “CFTC”) approved the publication of two releases (the “Final Rules”) on November 25, 2019, adopting final amendments to Part 4 of the CFTC Rules which codify and expand a number...more

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