News & Analysis as of

Commodity Pool Dodd-Frank Wall Street Reform and Consumer Protection Act No-Action Relief

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 -
Morgan Lewis

CFTC Staff Clarifies Registration Relief Available to Non-US Asset Managers

Morgan Lewis on

No-action relief confirms that non-US asset managers may rely on an exemption from CFTC registration when trading uncleared swaps in the United States for the accounts of their non-US clients, an issue that had been in doubt...more

Dechert LLP

CFTC Staff Issues No-Action Relief Helpful for Non-U.S. Commodity Pool Operators and Commodity Trading Advisors

Dechert LLP on

The U.S. Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) provided no-action relief on February 12, 2016 to commodity pool operators (CPOs) and commodity trading advisors...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Derivatives in Review - July 2014

Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more

Eversheds Sutherland (US) LLP

CFTC Issues No-Action Relief from Commodity Pool Operator Registration Requirements for Business Development Companies

On December 4, 2012, the Commodity Futures Trading Commission’s (CFTC’s) Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from commodity pool operator (CPO) registration requirements for...more

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