News & Analysis as of

Commodity Trading Advisors (CTAs) Commodities

Cadwalader, Wickersham & Taft LLP

CFTC Issues Proposed Rule to Modify Regulation 4.7 Exemptions

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

Cadwalader, Wickersham & Taft LLP

CFTC Further Expands the Definition of CTA

On August 29, 2023, the U.S. District Court for the Western District of Texas entered a consent order ("Order") and imposed sanctions on Barelt Media and its owner Ryan Masten for operating an unregistered commodity trading...more

Fox Rothschild LLP

Updated 2023– Who Does What: Broker Dealers | Registered Investment Advisers | Commodities/Futures Entities

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I. Starting a Broker-Dealer- Becoming an owner of a broker-dealer (BD) is a time-consuming and expensive endeavor. Although the United States Securities and Exchange Commission (SEC) requires BD registration pursuant to the...more

Cadwalader, Wickersham & Taft LLP

CFTC Sanctions Registered CTA for Operating Unregistered SEF

On September 26, the Commodity Futures Trading Commission (“CFTC”) published an order settling charges against Asset Risk Management, LLC (“ARM”), a registered commodity trading advisor (“CTA”) headquartered in Houston,...more

Cadwalader, Wickersham & Taft LLP

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

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

Dechert LLP

SEC Proposes Rule Changes Applicable to BDCs’ Use of Derivatives and Other Transactions

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The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a rule proposal related to the use of derivatives and certain other transactions by companies that have elected to be...more

Dechert LLP

New NFA Filing Obligations for Investment Advisers to BDCs Trading Commodity Interests Require Action as Soon as Practicable After...

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The Commodity Futures Trading Commission published in the Federal Register on December 10, 20191 amendments to five different aspects of the regulatory framework applicable to certain commodity pool operators (CPOs) and...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Proposes to Simplify, Modernize Commodity Pool Operator and Commodity Trading Advisor Regulations

On October 18, 2018, the Commodity Futures Trading Commission (CFTC) published a proposal in the Federal Register (Proposed Rule) to amend several key compliance and registration regulations governing commodity pool operators...more

Dechert LLP

CFTC Proposes Amendments to Regulatory Framework for Certain CPOs and CTAs and New Exemption for CPOs of Non-U.S. Pools

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The Commodity Futures Trading Commission issued a Notice of Proposed Rulemaking on October 9, 2018 to amend certain aspects of the current regulatory framework applicable to commodity pool operators (CPOs) and commodity...more

Mayer Brown Free Writings + Perspectives

CPO and CTA Rule Proposals

Earlier this month, the Commodity Futures Trading Commission proposed rules that would codify certain relief provided to commodity pool operators and commodity trading advisors in the post Dodd-Frank Act years....more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on CFTC Proposed CPO and CTA Regulations, Brexit Statutory Instruments and...

CFTC - CFTC Approves Proposed Regulations for CPOs and CTAs - On October 9, the Commodity Futures Trading Commission approved proposed rules intended to simplify regulations for commodity pool operators (CPOs) and...more

Kramer Levin Naftalis & Frankel LLP

New Disclosure Rules Enhance Crypto Investor Protection

Amid concerns that many investors may not fully understand the risks associated with virtual currencies, or the limits of regulatory oversight, the National Futures Association (NFA) recently issued an interpretive notice...more

Dechert LLP

Federal Court Ruling Recognizes CFTC Jurisdiction over Cryptocurrencies as Commodities

Dechert LLP on

The U.S. Commodity Futures Trading Commission (CFTC) scored a victory in its effort to assert jurisdiction over portions of the cryptocurrency and initial coin offering (ICO) markets last week, as a federal district judge...more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

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The U.S. federal securities laws and the rules of U.S. self regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

Dechert LLP

Bitcoin Futures Trading Commences; Implications for Funds and Registered CPOs and CTAs

Dechert LLP on

The Chicago Mercantile Exchange (CME) and the CBOE Futures Exchange (CFE) on December 1, 2017 self-certified contracts for bitcoin futures products with the U.S. Commodity Futures Trading Commission (CFTC). Additionally, on...more

Dechert LLP

Financial Services Quarterly Report - Second Quarter 2017: U.S. CFTC Takes Steps to Modernize Rules and Operations and to Reduce...

Dechert LLP on

Against a backdrop of changing markets, rapidly evolving technology and increased jurisdiction, the U.S. Commodity Futures Trading Commission (CFTC) – the regulatory agency with responsibility for oversight of the U.S....more

Morgan Lewis

Deadline Approaches for Annual CPO/CTA Exemption Filings

Morgan Lewis on

Firms must affirm their exemption or exclusion from CPO or CTA registration on the National Futures Association’s Exemption Filing System by February 29....more

Proskauer Rose LLP

CFTC Grants Relief to Family Offices from Registration as Commodity Trading Advisor

Proskauer Rose LLP on

On November 5, 2014, the U.S. Commodity Futures Trading Commission (CFTC) issued a no-action letter granting relief from registration as a commodity trading advisor (CTA) to family offices that qualify for the family office...more

Katten Muchin Rosenman LLP

CFTC Adopts Final Harmonization Rules for Registered Investment Company Advisers Required to Register as CPOs Under Regulation...

On August 13, 2013, the Commodity Futures Trading Commission issued its final rules (“Final Rules”) applicable to registered investment companies now required to dually register as commodity pool operators (“Dually-Registered...more

Katten Muchin Rosenman LLP

NFA Issues Notice Regarding CTA Reporting Requirements

National Futures Association (NFA) issued a notice to members relating to reporting requirements for commodity trading advisors (CTAs)...more

Eversheds Sutherland (US) LLP

Legal Alert: The CPO and CTA Regulatory Regimes: What Operators of and Advisers to Commodity Pools Should Expect in 2013

There were a number of significant changes to the regulatory regime for commodity pool operators (CPOs) and commodity trading advisors (CTAs) in 2012. As a result of these changes, various types of collective investment...more

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