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Commodity Pool › Reporting Requirements

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 -
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

Akin Gump Strauss Hauer & Feld LLP

Update (2): The NY LLC Transparency Act and Corporate Transparency Act’s Impact on Private Fund Managers

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In the weeks since publishing our original alert, FinCEN released several frequently asked questions (FAQs) on the application of the Corporate Transparency Act (CTA). Private fund managers are likely to find two of these...more

Morgan Lewis

National Futures Association Proposes New Reporting Requirements for Commodity Pool Operators

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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

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

Morgan Lewis

CFTC Streamlines Form CPO-PQR

Morgan Lewis on

The US Commodity Futures Trading Commission (CFTC or Commission) unanimously approved amendments to Form CPO-PQR on October 6 that will streamline the form beginning with the March 31, 2021 reporting period. Here is how the...more

Morgan Lewis

CFTC Proposes Streamlined Version of Form CPO-PQR

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The Commodity Futures Trading Commission (CFTC) has proposed amendments to Form CPO-PQR, streamlining the form but requiring commodity pool operators (CPOs) to report legal entity identifiers to facilitate the CFTC’s data...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Proposes to Narrow its CPO-PQR to Conform to the NFA Form PQR and Add LEIs

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On April 14, 2020, the Commodity Futures Trading Commission (CFTC) proposed, among other things, to narrow and revise the scope of information that it collects from commodity pool operators (CPOs) on its Form CPO-PQR to: ...more

Perkins Coie

Statement of DSIO Director Joshua B. Sterling on Supporting Innovation in Digital Asset Products, including Pooled Investment...

Perkins Coie on

The CFTC DSIO Division Director issued a statement reminding the industry that pooled investment vehicles that trade futures, swaps, and other commodity interests that reference digital assets like Bitcoin and stablecoins are...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

Akin Gump Strauss Hauer & Feld LLP

CFTC and NFA Year End Regulatory Updates

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• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - January 2019

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The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

K&L Gates LLP

CFTC Proposes to Codify Relief for CPOs and CTAs

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Introduction - The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) is proposing amendments to its regulations governing commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) to codify...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Proposes to Codify Existing Staff-Issued Relief from Registration and Other Compliance Requirements for CPOs and CTAs

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• CPOs and CTAs of offshore commodity pools, family offices and business development companies would be exempt from registering with the CFTC. • Certain registered CPOs and CTAs would not be required to file Form CPO-PQR...more

Dechert LLP

Registered CPOs and CTAs: Prepare for June 30 Changes to NFA Forms PQR and PR

Dechert LLP on

Beginning with the second quarter 2017 filings, registered commodity pool operators (CPOs) and commodity trading advisors (CTAs) (collectively, Registrants) will need to report financial information regarding their own...more

Broker-Dealer Compliance + Regulation

CFTC Approves Final Rule Amendments to CPO Financial Report Regulations

Broker-Dealer Compliance + Regulation on

On November 21, 2016, the U.S. Commodity Futures Trading Commission (CFTC) approved final rule amendments to its regulations that allow commodity pool operators (CPOs) to use certain additional alternative generally accepted...more

Morgan Lewis

CFTC Staff Exempts Certain Commodity Trading Advisors from Form CTA-PR Reporting

Morgan Lewis on

The reporting relief applies to commodity trading advisors that do not “direct” trading of any client commodity interest trading accounts. On July 23, the CFTC’s Division of Swap Dealer and Intermediary Oversight issued...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review - November 12, 2013

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CFTC Proposed Rule on Commodity Pools - On November 5, the CFTC issued a proposed rule that would require that all registered introducing brokers (IBs), commodity pool operators (CPOs) and commodity trading advisors...more

Broker-Dealer Compliance + Regulation

CFTC Adopts “Substituted Compliance” Approach for Registered Investment Companies that Are Commodity Pools

Broker-Dealer Compliance + Regulation on

In a dramatic change of course, the Commodity Futures Trading Commission (CFTC) adopted final rules that apply a “substituted compliance” approach for disclosure and compliance obligations of registered investment companies...more

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