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Commodity Pool › Interpretive Letters › Commodities Futures Trading Commission

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”

Morrison & Foerster LLP on

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

Katten Muchin Rosenman LLP

CFTC Provides Guidance on Bona Fide Hedging for Rule 4.5 Compliance

Katten Muchin Rosenman LLP on

On October 12, CFTC Staff Interpretive Letter 12-19 provided guidance with respect to the interpretation of bona fide hedging under CFTC Regulations. Under Rule 4.5 of the CFTC’s Regulations, advisers may be excluded from the...more

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