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Commodity Pool Dodd-Frank Wall Street Reform and Consumer Protection Act Securitization Vehicles

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 -
Morrison & Foerster LLP

The CFTC’s Interpretive Letters Regarding Securitizations, REITs and the Definition of “Commodity Pool”

In two interpretive letters issued on October 11, 2012 (collectively, the “Interpretive Letters”), the Division of Swap Dealers and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the...more

Dechert LLP

Unintended Consequences Avoided? CFTC Provides Relief for Certain Securitization Vehicles

Dechert LLP on

Last Thursday, the U.S. Commodity Futures Trading Commission (“CFTC”) responded to ASF’s and SIFMA’s requests for relief from the new CFTC rules which implemented certain Dodd-Frank amendments that brought swaps within the...more

Stinson - Corporate & Securities Law Blog

CFTC Sheds Light on Definition of Commodity Pool

Perhaps one of the most important questions since the Dodd-Frank Act is “What is a commodity pool”? Close behind is “Who is a commodity pool operator”? The CFTC has begun to shed light on these questions by issuance of...more

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