News & Analysis as of

Commodity Pool Operator › Commodities Futures Trading Commission › Securities and Exchange Commission (SEC)

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 -
Vedder Price

2020 Annual Compliance Obligation Reminders

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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

Proskauer Rose LLP

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

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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

Dechert LLP

Federal Court Ruling Recognizes CFTC Jurisdiction over Cryptocurrencies as Commodities

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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

K&L Gates LLP

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

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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

Morgan Lewis

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

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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

Goodwin

Financial Services Weekly News Roundup - September 2014

Goodwin on

In This Issue: The CFTC provided long-awaited exemptive relief for commodity pool operators that wish to offer their funds in private offerings using general solicitation under Rule 506(c) of the SEC’s Regulation D. ...more

Morrison & Foerster LLP

Investment Management Legal + Regulatory Update -- September 2014

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In This Issue: - Regulation: Long-Awaited Money Market Fund Rules Adopted - SEC Staff Offers Guidance Regarding Investment Advisers and Proxy Advisory Firms - SEC Staff Closes Loophole on BDC Asset...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

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Council of EU Presidency Compromise Proposal on Benchmark Regulation - On September 10, the Presidency of the Council of the EU published its first compromise proposal (dated September 9, 2014) relating to the European...more

Katten Muchin Rosenman LLP

CFTC Aligns CPO Regulation With JOBS Act, Provides Other Guidance for CPOs

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The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) recently issued several letters affecting commodity pool operators (CPOs): JOBS Act Harmonization: On September 9,...more

Dechert LLP

CFTC Permits Additional Third-Party Recordkeepers for Registered CPOs

Dechert LLP on

The Division of Swap Dealer and Intermediary Oversight (DSIO Staff) of the U.S. Commodity Futures Trading Commission (CFTC) issued exemptive relief on September 8, 2014 to permit a registered commodity pool operator (CPO) to...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 36

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In this issue: - Bylaw of Delaware Corporation Providing for Exclusive Forum in North Carolina Upheld - FINRA Board to Consider Rule Proposals Regarding Private Trading Platforms - CBOE and C2 in...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Publishes Long-Awaited JOBS Act Relief

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The staff of the Commodity Futures Trading Commission (CFTC) published a no-action letter on September 9, 2014 (available here) that permits certain commodity pool operators (CPOs) to conduct general solicitation in private...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 23

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In this issue: - SEC Chair Gives Speech on Equity Market Structure - New CFTC Commissioners Confirmed; Chairman Sworn In - CFTC Extends No-Action Relief for Certain Transaction-Level Requirements...more

K&L Gates LLP

CFTC Provides Streamlined No-Action Relief Filing Procedure to Certain Commodity Pool Operators Who Delegate Responsibilities to...

K&L Gates LLP on

The Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (“CFTC” or the “Commission”) recently issued CFTC Letter No. 14-69 (May 12, 2014) (the “Letter”), which...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Orrick, Herrington & Sutcliffe LLP on

EU Commission Sends Statement of Objections to Three Banks in Cartel Investigation - On May 20, the European Commission announced that it has sent a statement of objections to Credit Agricole, HSBC and JP Morgan for...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume VIII, Issue 46

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In this issue: - SEC Division of Corporation Finance Issues 14 New C&DIs Relating to “Bad Actor” Rules - NASDAQ Proposes Change to Listing Rules Regarding Compensation Committee Independence - FINRA...more

Perkins Coie

Financial Services Bulletin: Action At The CFTC And CFPB

Perkins Coie on

CFTC Proposes Registered Futures Association Membership Rules - On Friday, November 8, 2013, the Commodity Futures Trading Commission (the "CFTC") proposed amending its regulations to require that all persons...more

Orrick, Herrington & Sutcliffe LLP

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

Orrick, Herrington & Sutcliffe LLP on

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

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - November 8, 2013

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In this issue: - CFTC Adopts Rules for Segregation of Initial Margin for Uncleared Swaps - CFTC Extends Time-Limited Relief for Foreign Exchange Swaps - CFTC Approves Position Limits Proposals -...more

Morrison & Foerster LLP

Disclosure Requirements and Advertising Rules for CPOs

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On August 13, 2013, the Commodity Futures Trading Commission (the “CFTC”) adopted final rule amendments to accept compliance with the disclosure, reporting and recordkeeping rules of the Securities and Exchange Commission...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - September 13, 2013

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In this issue - - Federal Agencies Seek Comment on Joint Proposed Rule Regarding Credit Risk Retention - SEC Grants Request for No-Action Relief with Respect to Multi-Day Pre-Fail and Post-Fail Credit Under Rule...more

K&L Gates LLP

CFTC Adopts Harmonization Rules for Investment Advisers that are Commodity Pool Operators of Registered Funds

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On August 13, 2013, the Commodity Futures Trading Commission (“CFTC”) adopted long-awaited harmonization rules (“Harmonization Rules”) for operators of registered investment companies (“Registered Funds”) that are subject to...more

Goodwin

CFTC Harmonizes Rules Applicable to CPOs of Registered Investment Companies and Modifies Requirements for All CPOs

Goodwin on

The CFTC adopted rule amendments (the “Harmonization Rule”) designed to harmonize certain CFTC compliance obligations that apply to commodity pool operators (“CPOs”) of investment companies registered under the Investment...more

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