News & Analysis as of

Commodity Pool Operator

Commodity Pool Operators are individuals who manage and secure capital for commodity pools. Most commodity pool operators are required to register as CPOs, unless they qualify for a registration exemption under... more +
Commodity Pool Operators are individuals who manage and secure capital for commodity pools. Most commodity pool operators are required to register as CPOs, unless they qualify for a registration exemption under the Commodity Futures Trading Commission regulations.  less -
Akin Gump Strauss Hauer & Feld LLP

CFTC Staff Extends Relief with Respect to Certain Position Limit Aggregation Requirements

Akin Gump Strauss Hauer & Feld LLP on

Key Points - Until August 12, 2025, CPOs and CTAs may continue to file position limit disaggregation notices upon request, rather than prospectively, and exempt CTAs may continue to rely upon the “independent account...more

K&L Gates LLP

And One More Thing: The NFA Adopts Rules Establishing CPO Notice Filing Requirements when a CPO is Unable to Fulfill its...

K&L Gates LLP on

Introduction - On 13 April 2021, the National Futures Association (NFA) released an Interpretive Notice entitled Compliance Rule 2-50: CPO Notice Filing Requirements (Interpretive Notice)....more

Morrison & Foerster LLP

UK Opt-Out Class Actions – A New (Anti) Competitive Landscape

Morrison & Foerster LLP on

On 11 December 2020, the UK Supreme Court handed down its highly anticipated judgment in the case of Mastercard v Merricks. The case concerned the certification procedure for US-style ‘opt-out’ collective (class action)...more

Morgan Lewis

CFTC Proposes Relief for Non-US Commodity Pool Operators

Morgan Lewis on

The US Commodity Futures Trading Commission has proposed amendments to CFTC Regulation 3.10(c)(3) to allow non-US commodity pool operators to claim an exemption from registration with respect to their offshore commodity pools...more

Akin Gump Strauss Hauer & Feld LLP

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

Akin Gump Strauss Hauer & Feld LLP on

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

Alston & Bird

CFTC Issues No-Action Letter Offering Regulatory Relief for CPOs

Alston & Bird on

Our Investment Management Team outlines how the Commodity Futures Trading Commission will allow commodity pool operators to delay their reporting obligations during the coronavirus pandemic....more

Vedder Price

2020 Annual Compliance Obligation Reminders

Vedder Price on

Investment advisers registered with the U.S. Securities and Exchange Commission (SEC) or with a state, as well as commodity pool operators and commodity trading advisors registered with the U.S. Commodity Futures Trading...more

K&L Gates LLP

Derivatives Updates: 2019 Washington D.C. Investment Management Conference

K&L Gates LLP on

OVERVIEW - - Market Developments: Regulatory and Compliance - Market Developments: Transactional and Marketplace ...more

Hogan Lovells

CPO Basics – What’s all the fuss about?

Hogan Lovells on

Compulsory Purchase Orders might not seem the most glamorous of topics, but with the urgent need for more homes, and a new Prime Minister showing great enthusiasm for big infrastructure projects, now’s the time to get to...more

Akin Gump Strauss Hauer & Feld LLP

NFA to Require Swap Proficiency Testing for Associated Persons of CPOs and CTAs Who Engage in Swaps Activity

Akin Gump Strauss Hauer & Feld LLP on

• By January 31, 2021, all swap associated persons of registered CPOs and CTAs must take and pass the NFA’s new swaps proficiency requirements. • The swaps proficiency requirements mirror the proficiency testing long...more

K&L Gates LLP

CFTC Proposes to Codify Relief for CPOs and CTAs

K&L Gates LLP on

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

Proskauer Rose LLP

CFTC Proposes to Streamline CPO and CTA Regulations by Codifying Prior Relief

Proskauer Rose LLP on

On October 9, 2018, the Commodity Futures Trading Commission (CFTC) proposed new rules in connection with the CFTC's Project KISS Initiative directed at simplifying Commodity Pool Operator (CPO) and Commodity Trading Advisor...more

Orrick - Finance 20/20

CFTC Proposes to Streamline Regulations for Commodity Pool Operators and Commodity Trading Advisors

Orrick - Finance 20/20 on

On October 9, the Commodity Futures Trading Commission (“CFTC“) unanimously approved proposed rules as a part of its KISS initiative to simplify regulations for commodity pool operators (“CPOs“) and commodity trading advisors...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

Akin Gump Strauss Hauer & Feld LLP on

• 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

Morgan Lewis

A Light Lift: CFTC Proposes to Codify Existing No-Action Relief and Other Relief Applicable to CPOs and CTAs

Morgan Lewis on

The US Commodity Futures Trading Commission has proposed a rule to streamline its regulation of commodity pool operators and commodity trading advisors, with most proposed amendments codifying, and in some cases broadening,...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

Eversheds Sutherland (US) LLP

Affirmations of CPO and CTA registration exemptions are due by March 1, 2018

Eversheds Sutherland (US) LLP on

Persons claiming exemptions from registration as a commodity pool operator (CPO) or a commodity trading advisor (CTA) must affirm their exemptions by March 1, 2018. Pursuant to Commodity Futures Trading Commission (CFTC)...more

Dechert LLP

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

Dechert LLP on

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

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

K&L Gates LLP

CFTC Permits Unaudited Financial Statements Upon Liquidation of a Series of a Pool That is Also a Registered Investment Company

K&L Gates LLP on

The Commodity Futures Trading Commission (“CFTC” or “Commission”) has provided general exemptive relief to persons registered as commodity pool operators (“CPO”) under the Commodity Exchange Act that operate commodity pools...more

Goodwin

Financial Services Weekly News - December 2016

Goodwin on

Editor's Note - OCC to Move Forward with Federal FinTech Charter. In a development foreshadowed in the April 6, June 29 and September 14 editions of the Roundup, on December 2, the Office of the Comptroller of the...more

Orrick - Finance 20/20

CFTC Unanimously Approves Final Rule Amendments to Its Regulations Regarding CPO Financial Reports

Orrick - Finance 20/20 on

On November 21, 2016, the U.S. Commodity Futures Trading Commission (“CFTC“) announced that it had approved amendments to its regulations applicable to commodity pool operators and the financial reports they are required to...more

Morgan Lewis

NFA Proposal Would Require CFTC-Registered Asset Managers to Report on Financial Condition

Morgan Lewis on

The National Futures Association’s (NFA’s) latest proposal would require registered commodity pool operators and commodity trading advisors to provide new information about their financial condition in quarterly reports to...more

Orrick - Finance 20/20

CFTC Extends Comment Period on Proposed Amendments to Regulation 4.22 Regarding CPO Annual Reports

Orrick - Finance 20/20 on

On August 30, 2016, the Commodity Futures Trading Commission extended the comment period for proposed amendments to a regulation regarding Annual Reports from commodity pool operators....more

Broker-Dealer Compliance + Regulation

CFTC Proposed Registration Relief for Non-U.S. Futures Commission Merchants, Commodity Pool Operators, Commodity Trading Advisors...

Broker-Dealer Compliance + Regulation on

On July 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) proposed amendments to its rules (“Proposed Rules”) that loosen the conditions for exemption from registration as a futures commission merchant (“FCM”),...more

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